- 10 - worthlessness of a loan for the year prior to the year in which the repossession occurred. No facts extant at the end of May 1990, 1991, and 1992, have been established by petitioners that would support the disputed claimed bad debt deductions for those years. Inventory Write-Downs Section 471 provides that a taxpayer should use a method of accounting for inventory as prescribed by the Secretary that clearly reflects the taxpayer’s income. Inventory should be recorded in a legible manner, properly computed, summarized, and kept as part of the accounting records of the taxpayer. Sec. 1.471-2(e), Income Tax Regs. When respondent determines that a taxpayer’s method of accounting for inventory under section 471 is improper, the taxpayer has a heavy burden of proving that respondent’s determination is plainly arbitrary and constitutes an abuse of discretion. Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 532-533 (1979). The Secretary’s regulations provide that the lower of cost or market is an acceptable method of accounting for inventory. Sec. 1.471-2(c), Income Tax Regs. Under the lower of cost or market method, as of the end of an inventory period (e.g., as of yearend) the cost of each item of inventory is compared to its market value, and the lower ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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