Best Auto Sales, Inc. - Page 10




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          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 of              





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Last modified: May 25, 2011