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Tax Home > Resources > Tax Accounting > Regulation and Administration > AICPA Comments on LIFO Technical Advice Memo
May 2, 2006
AICPA Comments on LIFO Technical Advice Memo

Robert M. Brown, Esq.

Associate Chief Counsel (Income Tax & Accounting)

Office of Chief Counsel

Internal Revenue Service

1111 Constitution Avenue, NW

Washington, D.C. 20224

 

Dear Mr. Brown:

 

The American Institute of Certified Public Accountants (AICPA) is writing this letter regarding TAM 200603027, which holds that a taxpayer’s LIFO election must be extended to all items within a dollar-value LIFO pool under the inventory price index computation (IPIC) pooling method. These comments were developed by members of our Tax Accounting TRP and approved by the AICPA Tax Executive Committee.

 

As indicated in the attached comments, we have serious concerns that the conclusion in the TAM is inconsistent with a plain reading of the section 472 regulations and violates basic policy ramifications of the LIFO IPIC method rules.

 

We appreciate your consideration of our comments in this matter, and we are available to discuss this matter at your convenience. If you have any questions, please contact me at tpurcell@creighton.edu; or Christine Turgeon, Chair, AICPA Tax Accounting, at christine.turgeon@us.pwc.com; or George White, AICPA Technical Manager, at gwhite@aicpa.org.

 

Sincerely,

 

Thomas J. Purcell III

Chair, AICPA Tax Executive Committee

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Copyright © 2006 by the American Institute of Certified Public Accountants, Inc., New York, New York.