- 11 - the two is recorded as the basis of that item of inventory for tax purposes. Sec. 1.471-4(c), Income Tax Regs. If as of yearend the market value of inventory is lower than its cost, the taxpayer “writes down” the basis of the inventory to the lower market value, thereby reducing gross income. See, e.g., Thor Power Tool Co. v. Commissioner, supra at 530. The write-down of inventory from cost to market value based on mere estimates is not allowable. Sec. 1.471-2(f)(1), Income Tax Regs. An official guide for used automobiles may be used to ascertain the market value of used automobile inventory for purposes of determining the lower of cost or market value. Brooks-Massey Dodge, Inc. v. Commissioner, 60 T.C. 884, 895 (1973) (citing Rev. Rul. 67-107, 1967-1 C.B. 115). Without objective evidence such as books and records to substantiate that item-by-item comparisons of cost to market value were conducted by ABC in the calculation of its yearend inventory write-downs, we will not disturb respondent’s determination to disallow ABC’s claimed inventory write-downs. See Thor Power Tool Co. v. Commissioner, supra at 536; Import Specialties, Inc. v. Commissioner, T.C. Memo. 1982-41. The testimony of ABC’s president that at yearend he made estimates of the value of the automobiles does not provide a basis on which the claimed inventory write-downs can be allowed in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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