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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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