- 23 - Petitioner was not required to determine with absolute certainty the useful life of the garments and dust control items; rather, petitioner was permitted to make reasonable approximations of the useful life of the items based on a reasonable relationship to petitioner’s business practices. Respondent’s arguments do not overcome petitioner’s evidence that supported the reasonableness of its methodology. Petitioner’s garment tracking system was used to track the processing of garments, but it did not provide information on the service life of each garment. Petitioner’s witness testified that the tracking of millions of garments and dust control items in service would not have been administratively or economically feasible. Any laboratory test, whether or not conducted, would have produced results that documented the durability of a fabric or garment, and, thus, the test results would reflect the physical life of the garment, rather than the useful life. Petitioner’s representations that certain clean room garments could have a service life of up to 4 years were made subsequent to the years in issue, see Banc One Corp. v. Commissioner, 84 T.C. at 499-500, and do not take into account the nonphysical events that caused a garment to be withdrawn from service. As to petitioner’s use of the 65-percent polyester and 35-percent cotton garments, petitioner’s industry expert explained that the industry did not use the 65-percent polyesterPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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