Mountain State Ford Truck Sales, Inc. v. Commissioner
United States Tax Court
Company M (M), a heavy truck dealer, purchased heavy truck parts and accessories (parts) from the manufacturers of those parts and sold them to its customers.
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Company M (M), a heavy truck dealer, purchased heavy truck parts and accessories (parts) from the manufacturers of those parts and sold them to its customers. M, which is required to use inventories pursuant to sec. 471, I.R.C., made elections under sec. 472, I.R.C., effective as of the close of its taxable year 1980, to apply the last-in, first-out (LIFO) method of inventory accounting (LIFO method) with respect to its parts inventory, to use the dollar-value LIFO method, to calculate the price index for its parts pool pursuant to the link-chain method, and to use the "most recent purchases…
1Opinion of the Court
CHIECHI, Judge:
Respondent determined S corporation adjustments for 1991 to the ordinary income of Mountain State Ford Truck Sales, Inc. (Mountain State Ford), in the amount of $504,013.
The issues remaining for decision are:(1) Did respondent abuse respondent’s discretion in determining that Mountain State Ford’s method of using replacement cost in valuing its parts inventory under the LIFO method does not clearly reflect income? We hold that respondent did not;(2) even though we have held that respondent did not abuse respondent’s discretion in making the determination described above, did…
2Cases cited12 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Commissioner v. Keystone Consolidated Industries, Inc.Supreme Court of the United States · 1993
- Prabel v. CommissionerUnited States Tax Court · 1988
- Bruce A. And Marianne S. Prabel v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1989
- Hutzler Bros. Co. v. CommissionerUnited States Tax Court · 1947
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3Cited by2 opinions
- Mountain State Ford Truck Sales, Inc. v. CommissionerUnited States Tax Court · 1999
- Mountain State Ford Truck Sales, Inc., E.P. O'Meara, Tax Matters Person v. CommissionerUnited States Tax Court · 1999