Coggin Automotive Corporation - Page 28




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          expressed herein, and to the extent not discussed above, we find            
          them to be without merit.                                                   
               The deficiencies set forth in the notices of deficiency are            
          based on petitioner’s failure to recapture its LIFO reserves of             
          $5,077,808 into its income.  Based on our holding that $4,792,372,          
          rather than $5,077,808, of the dealerships’ pre-S election LIFO             
          reserves must be included in petitioner’s income, the tax                   
          deficiency is $408,300 (rather than $432,619), pursuant to                  
          respondent’s alternative position, for each of the years under              
          consideration.  Accordingly,                                                


          Decision will be                                                            
          entered for respondent                                                      
          in the reduced amounts                                                      
                                                  for the years under                
                                                   consideration.                     




















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Last modified: May 25, 2011