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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events that caused a garment to be withdrawn from service.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 polyester
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