Dow A. and Sandra E. Huffman, et al. - Page 23

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          shown on those returns due to the accountant’s error.  Respondent           
          revalued the members’ inventories for the election and following            
          years (beginning for Nissan and Volkswagen with 1979 and for Dodge          
          and Chrysler with 1990 and ending for all four corporations with            
          1999).  Those revaluations caused respondent to make adjustments to         
          the members’ gross incomes for those years.  For each inventory             
          pool, for each year, respondent proceeded as follows:  He first             
          calculated the correct yearend LIFO inventory value.  Based on the          
          correct yearend LIFO inventory value, he next calculated the                
          correct yearend LIFO reserve.  He then subtracted the correct               
          yearend LIFO reserve from the yearend LIFO reserve calculated by            
          the accountant.  The difference, generally a positive number (the           
          adjustment to ending inventory), is the amount that he calculated           
          would have to be added to or subtracted from (generally added to)           
          the yearend LIFO inventory value computed by the accountant to              
          conform that value with the correct yearend LIFO value.  To                 
          calculate any necessary adjustment to gross income for the year,            
          respondent subtracted from the adjustment to ending inventory the           
          similarly calculated adjustment that he had made for the prior year         
          (except, of course, for the first year he commenced making                  
          adjustments).  The difference was usually positive and would, thus,         
          increase gross income (by, in effect, decreasing the cost of goods          
          sold from the pool).                                                        







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