Legal Opinion

Richardson Inv. v. Commissioner

United States Tax Court

Decided May 11, 1981No. Docket No. 3261-79PublishedCited by 8 opinions

Petitioner, a Ford Motor Co. franchised dealer, maintained its inventory on the LIFO dollar-value, link-chain method utilizing one pool for new cars and new trucks. Held, sec. 1.472-8(c), Income Tax Regs., requires petitioner to utilize one pool for new cars and a separate pool for new trucks.

1Opinion of the Court

Sterrett, Judge:

By statutory notice dated December 15, 1978, respondent determined deficiencies in income tax as follows:

Year ended Dec. 31— Deficiency

1971.$109,701.31

1972. 11,791.00

1974 . 20,900.50

The years 1971 and 1972 are in issue only because of petitioner’s net operating loss carryback. The primary issue presented is whether petitioner, a retail automobile dealership engaged primarily in the purchase and retail sale of new and used cars and trucks, properly adopted the use of a single LIFO inventory pool in computing inventory values pursuant to the dollar-value, link-chain LIFO method…

2Cases cited5 opinions

  1. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  2. Lucas v. Kansas City Structural Steel Co.Supreme Court of the United States · 1930
  3. Fox Chevrolet, Inc. (Maryland) v. CommissionerUnited States Tax Court · 1981
  4. Klein Chocolate Co. v. CommissionerUnited States Tax Court · 1959
  5. Wendle Ford Sales, Inc. v. CommissionerUnited States Tax Court · 1979

3Cited by8 opinions

  1. Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
  2. Amity Leather Products Co. v. CommissionerUnited States Tax Court · 1984
  3. Consolidated Mfg. v. CommissionerUnited States Tax Court · 1998
  4. Amity Leather Products Co. v. CommissionerUnited States Tax Court · 1984
  5. Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person v. CommissionerUnited States Tax Court · 1998

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