- 28 - In reaching all of our holdings herein, we have considered all arguments made by the parties, and to the extent not mentioned above, we find them to be irrelevant or without merit.9 Decision will be entered under Rule 155. 9 We note that secs. 611 and 631 and the regulations thereunder contain special rules of accounting for the timber industry. See secs. 611, 631; sec. 1.611-3, Income Tax Regs. (relating to cost depletion of timber), sec. 1.631-1, Income Tax Regs. (creating an election to consider the cutting of timber as a sale or exchange); see also RLC Indus. Co. v. Commissioner, 98 T.C. 457 (1992) (analyzing taxpayer’s method of computing timber depletion under sec. 611), affd. 58 F.3d 413 (9th Cir. 1995). Neither party argued in its briefs that these code sections are dispositive of the issues presented in this case. Additionally, neither party addressed the interplay of these code sections with secs. 447 and 448, or the rules regarding inventory in the regulations under secs. 611 and 631. Accordingly, we will not address these issues. We note that while petitioner mentioned sec. 631(a) in passing in its reply brief, petitioner did not raise the aforementioned issues. Furthermore, we will not consider issues that are raised for the first time in a reply brief. See Foil v. Commissioner, 92 T.C. 376, 418 (1989), affd. 920 F.2d 1196 (5th Cir. 1990); Markwardt v. Commissioner, 64 T.C. 989, 997 (1975).Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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