Dow A. and Sandra E. Huffman, et al. - Page 22

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          illustrates the distortions:                                                
                                        LIFO inventory     LIFO inventory             
                                         undistorted        distorted                 
                                   Yr. 1   Yr. 2     Yr. 1   Yr. 2                    
          1.  Opening inventory         $100      $300      $100    $200              
          2.  Plus: Purchases               200     0        200       0              
          3.  Equals: Cost of goods                                                   
          available for sale            300       300       300     200               
          4.  Less: Closing inventory       300     0        200       0              
          5.  Equals: Cost of goods sold      0     300      100     200              
          6.  Sales                     0   300             0     300                 
          7.  Less: Cost of goods sold                                                
          (line 5.)                           0     300      100     200              
          8.  Equals: Gross Income                                                    
          from sales                    0       0     (100)    100                    
               It should be noted that, if T’s failure to index the year 1            
          increment were corrected as of the beginning of year 2 (increasing          
          her year 2 opening inventory to $300), without any concomitant              
          increase in her year 1 ending inventory, then $100 of gross income          
          would go unreported (T would have a phantom loss of that amount in          
          year 1 with no offsetting gain in year 2), unless an offsetting             
          section 481 adjustment were made in year 2 to correct that apparent         
          windfall.                                                                   
          Respondent’s Examination and Adjustments                                    
               –- The Examination                                                     
               Sometime after the members of the Huffman group filed their            
          1999 Federal income tax returns, respondent commenced an                    
          examination of those and prior returns.  Respondent identified              
          mistakes in the members’ beginning and ending inventory values              






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