Legal Opinion

Fox Chevrolet, Inc. (Maryland) v. Commissioner

United States Tax Court

Decided May 11, 1981No. Docket No. 11483-77PublishedCited by 64 opinions

Petitioner, a retail automobile dealership, elected the dollar-value LIFO method of computing its inventory. One pool was kept for all its new vehicles. Respondent contends that multiple pools are required corresponding to model lines of vehicles sold. Held, two separate pools are required to be maintained, one for new automobiles and another for new trucks.

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Petitioner, a retail automobile dealership, elected the dollar-value LIFO method of computing its inventory. One pool was kept for all its new vehicles. Respondent contends that multiple pools are required corresponding to model lines of vehicles sold. Held, two separate pools are required to be maintained, one for new automobiles and another for new trucks. Sec. 1.472-8(c), Income Tax Regs.Held, further: Respondent did not challenge petitioner's method of calculating a price index under the double-extension method until trial. Due to this untimeliness as well as the substantial prejudice…

1Opinion of the Court

Wilbur, Judge:

Respondent has determined the following deficiencies in petitioner’s Federal income tax:

Taxable period Deficiency

1972.$48,725

1973.79,284

1974.90,512

This case presents the following issues for our decision: (1) Whether petitioner, an automobile dealership engaged primarily in the purchase and retail sale of automobiles and trucks and which uses the dollar-value LIFO method of inventory valuation, may include all new vehicles in a single pool (or should include each model line of vehicle in a separate pool), and (2) whether respondent timely raised the issue of whether, assuming…

2Cases cited13 opinions

  1. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  2. Estate of Horvath v. CommissionerUnited States Tax Court · 1973
  3. Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
  4. Commissioner of Internal Revenue v. Chelsea Products, IncCourt of Appeals for the Third Circuit · 1952
  5. Rubin v. CommissionerUnited States Tax Court · 1971

8 more not listed; retrieve them via the Exa API.

3Cited by64 opinions

  1. Foster v. Comm'rUnited States Tax Court · 1983
  2. Drobny v. CommissionerUnited States Tax Court · 1986
  3. Church of Scientology v. CommissionerUnited States Tax Court · 1984
  4. Spencer D. Stewart, Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
  5. Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982

59 more not listed; retrieve them via the Exa API.

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