Best Auto Sales, Inc. - Page 11




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          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.              






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