Legal Opinion

Wendle Ford Sales, Inc. v. Commissioner

United States Tax Court

Decided June 7, 1979No. Docket No. 7614-76PublishedCited by 12 opinions

For its taxable year ending Dec. 31, 1974, petitioner, an automobile dealer, properly elected to change its inventory valuation with respect to its new car and new truck inventory from the first-in, first-out (FIFO) method to the last-in, first-out (LIFO) method. In so doing, petitioner properly employed the dollar-value and double-extension method as authorized by sec. 1.472-8(e), Income Tax Regs.

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For its taxable year ending Dec. 31, 1974, petitioner, an automobile dealer, properly elected to change its inventory valuation with respect to its new car and new truck inventory from the first-in, first-out (FIFO) method to the last-in, first-out (LIFO) method. In so doing, petitioner properly employed the dollar-value and double-extension method as authorized by sec. 1.472-8(e), Income Tax Regs. Under the double-extension method, items of inventory are placed into pools by types or classes of goods. Petitioner's base-year inventory pool for LIFO purposes was comprised of 1974 Ford…

1Opinion of the Court

Fay, Judge:

Respondent determined a deficiency of $2,939 in petitioner’s Federal income tax for 1973.

Concessions having been made, the issue for decision pertains to petitioner’s method of valuing its inventory. Specifically, we must decide whether petitioner, an automobile dealer who has properly elected the LIFO method of inventory valuation, must add to the cost of its “base-year” units an additional charge for catalytic converters and electronic (solid-state) ignition systems which were not present on base-year models.

FINDINGS OF FACT

Some of the facts have been stipulated and are so found.

P…

2Cases cited4 opinions

  1. Hutzler Bros. Co. v. CommissionerUnited States Tax Court · 1947
  2. Basse v. CommissionerUnited States Tax Court · 1948
  3. Klein Chocolate Co. v. CommissionerUnited States Tax Court · 1959
  4. F. S. Harmon Mfg. Co. v. CommissionerUnited States Tax Court · 1960

3Cited by12 opinions

  1. Fox Chevrolet, Inc. (Maryland) v. CommissionerUnited States Tax Court · 1981
  2. Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
  3. Amity Leather Products Co. v. CommissionerUnited States Tax Court · 1984
  4. Richardson Inv. v. CommissionerUnited States Tax Court · 1981
  5. Kohler Co. v. United StatesUnited States Court of Federal Claims · 1995

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