26 C.F.R. § 1.471-6

Inventories of livestock raisers and other farmers

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(a) A farmer may make his return upon an inventory method instead of the cash receipts and disbursements method. It is optional with the taxpayer which of these methods of accounting is used but, having elected one method, the option so exercised will be binding upon the taxpayer for the year for which the option is exercised and for subsequent years unless another method is authorized by the Commissioner as provided in paragraph (e) of § 1.446-1.

(b) In any change of accounting method from the cash receipts and disbursements method to an inventory method, adjustments shall be made as provided in section 481 (relating to adjustments required by change in method of accounting) and the regulations thereunder.

(c) Because of the difficulty of ascertaining actual cost of livestock and other farm products, farmers who render their returns upon an inventory method may value their inventories according to the “farm-price method”, and farmers raising livestock may value their inventories of animals according to either the “farm-price method” or the “unit-livestock-price method”. In addition, these inventory methods may be used to account for the costs of property produced in a farming business that are required to be capitalized under section 263A regardless of whether the property being produced is otherwise treated as inventory by the taxpayer, and regardless of whether the taxpayer is otherwise using the cash or an accrual method of accounting.

(d) The “farm-price method” provides for the valuation of inventories at market price less direct cost of disposition. If this method of valuation is used, it generally must be applied to all property produced by the taxpayer in the trade or business of farming, except as to livestock accounted for, at the taxpayer's election, under the unit livestock method of accounting. However, see § 1.263A-4(c)(3) for an exception to this rule. If the use of the “farm-price method” of valuing inventories for any taxable year involves a change in method of valuing inventories from that employed in prior years, permission for such change shall first be secured from the Commissioner as provided in paragraph (e) of § 1.446-1.

(e) The “unit-livestock-price method” provides for the valuation of the different classes of animals in the inventory at a standard unit price for each animal within a class. A livestock raiser electing this method of valuing his animals must adopt a reasonable classification of the animals in his inventory with respect to the age and kind included so that the unit prices assigned to the several classes will reasonably account for the normal costs incurred in producing the animals within such classes. Thus, if a cattle raiser determines that it costs approximately $15 to produce a calf, and $7.50 each year to raise the calf to maturity, his classifications and unit prices would be as follows: Calves, $15; yearlings, $22.50; 2-year olds, $30; mature animals, $37.50. The classification selected by the livestock raiser, and the unit prices assigned to the several classes, are subject to approval by the district director upon examination of the taxpayer's return.

(f) A taxpayer that elects to use the “unit-livestock-price method” must apply it to all livestock raised, whether for sale or for draft, breeding, or dairy purposes. The inventoriable costs of animals raised for draft, breeding, or dairy purposes can, at the election of the livestock raiser, be included in inventory or treated as property used in a trade or business subject to depreciation after maturity. See § 1.263A-4 for rules regarding the computation of inventoriable costs for purposes of the unit-livestock-price method. Once established, the methods of accounting used by the taxpayer to determine unit prices and to classify animals must be consistently applied in all subsequent taxable years. A taxpayer that uses the unit-livestock-price method must annually reevaluate its unit prices and adjust the prices either upward to reflect increases, or downward to reflect decreases, in the costs of raising livestock. The consent of the Commissioner is not required to make such upward or downward adjustments. No other changes in the classification of animals or unit prices may be made without the consent of the Commissioner. See § 1.446-1(e) for procedures for obtaining the consent of the Commissioner. The provisions of this paragraph (f) apply to taxable years ending after October 28, 2002.

(g) A livestock raiser who uses the “unit-livestock-price method” must include in his inventory at cost any livestock purchased, except that animals purchased for draft, breeding, or dairy purposes can, at the election of the livestock raiser, be included in inventory or be treated as property used in a trade or business subject to depreciation after maturity. If the animals purchased are not mature at the time of purchase, the cost should be increased at the end of each taxable year in accordance with the established unit prices, except that no increase is to be made in the taxable year of purchase if the animal is acquired during the last six months of that year. If the records maintained permit identification of a purchased animal, the cost of such animal will be eliminated from the closing inventory in the event of its sale or loss. Otherwise, the first-in, first-out method of valuing inventories must be applied.

(h) If a taxpayer using the “farm-price method” desires to adopt the “unit-livestock-price method” in valuing his inventories of livestock, permission for the change shall first be secured from the Commissioner as provided in paragraph (e) of § 1.446-1. However, a taxpayer who has filed returns on the basis of inventories at cost, or cost or market whichever is lower, may adopt the “unit-livestock-price method” for valuing his inventories of livestock without formal application for permission, but the classifications and unit prices selected are subject to approval by the district director upon examination of the taxpayer's return. A livestock raiser who has adopted a constant unit-price method of valuing livestock inventories and filed returns on that basis will be considered as having elected the “unit-livestock-price method”.

(i) If returns have been made in which the taxable income has been computed upon incomplete inventories, the abnormality should be corrected by submitting with the return for the current taxable year a statement for the preceding taxable year. In this statement such adjustments shall be made as are necessary to bring the closing inventory for the preceding taxable year into agreement with the opening complete inventory for the current taxable year. If necessary clearly to reflect income, similar adjustments may be made as at the beginning of the preceding year or years, and the tax, if any be due, shall be assessed and paid at the rate of tax in effect for such year or years.

[T.D. 6500, 25 FR 11726, Nov. 26, 1960, as amended by T.D. 8131, 52 FR 10084, Mar. 30, 1987; T.D. 8729, 62 FR 44551, Aug. 22, 1997; T.D. 8897, 65 FR 50650, Aug. 21, 2000; T.D. 9019, 67 FR 65698, Oct. 28, 2002]
Notes of Decisions
Cited in 30 cases, 1961–1998 · leading case: Auburn Packing Co. v. Comm'r, 60 T.C. 794 (Tax Ct. 1973).
Auburn Packing Co. v. Comm'r, 60 T.C. 794 (Tax Ct. 1973). · cites it 38× “OPINION Unlike other taxpayers, who are required to use inventories whenever the production or sale of merchandise is an income-producing factor, farmers are given the option of either adopting an inventory method of accounting or of using the cash or crop-cost methods of…”
Van Raden v. Comm'r, 71 T.C. 1083 (Tax Ct. 1979). · cites it 10× “Section 471 provides that whenever, in the opinion of the Secretary, the use of inventories is necessary to clearly reflect income, the taxpayer shall take inventories on such basis as the *1102 Secretary may prescribe, conforming as nearly as may be to the best accounting…”
Molsen v. Comm'r, 85 T.C. 485 (Tax Ct. 1985). · cites it 6× “, permits livestock raisers and farmers to value livestock inventory under the "unit-livestock-price method." Such method permits the livestock raiser to estimate the cost of the animals in inventory through a classification system based on the age and kind of the animal "so…”
Garth v. Comm'r, 56 T.C. 610 (Tax Ct. 1971). · cites it 8× “It states, in pertinent part, as follows: (a) A farmer may make his return upon an inventory method instead of the cash receipts and disbursements method.”
Maple Leaf Farms, Inc. v. Comm'r, 64 T.C. 438 (Tax Ct. 1975). · cites it 10× “471-6(a), Income Tax Regs. , and therefore is entitled to file its income tax returns on the cash receipts and disbursements method of accounting.”
Hi-Plains Enter., Inc. v. Comm'r, 60 T.C. 158 (Tax Ct. 1973). · cites it 8× “, and is entitled to file Federal income tax returns on the cash basis even though the corporate books are kept on the accrual basis.”
Rocco, Inc. v. Comm'r, 72 T.C. 140 (Tax Ct. 1979). · cites it 8× “, and both reported large operating losses for 1971, primarily because they did not reduce cost of goods sold by inventories, which losses the parent corporations utilized through the filing of a consolidated return for the entire controlled group.”
Packard v. Comm'r, 85 T.C. 397 (Tax Ct. 1985). · cites it 8× “The investment device chosen by petitioners centered around the special tax treatment afforded to farmers with regard to tax accounting for farm expenditures.”
Wagensen v. Comm'r, 74 T.C. 653 (Tax Ct. 1980). · cites it 4× “, a livestock raiser may complete his return using an inventory method of accounting rather than the cash receipts and disbursements method. Petitioner, in his brief, indicates that he used the unit-of-livestock method of accounting.”
Grynberg v. Comm'r, 83 T.C. 255 (Tax Ct. 1984). · cites it 2× “59 general provisions of section 162(a) and section 446(b); 7 while other cases concerning the deductibility of prepaid items arise not only under the general provisions of sections 162(a) and 446(b) but also under the authority of other Code provisions enacted to provide…”
Rojas v. Comm'r, 90 T.C. 1090 (Tax Ct. 1988). · cites it 2× “Moreover, the language quoted above provides no support for respondent's position in this case that deductions under *105 section 162(a) are premised on the sale of the product produced, rather than on consumption of the expensed asset in the taxpayer's business.”
Kennedy v. Comm'r, 89 T.C. 98 (Tax Ct. 1987). · cites it 4× “Respondent contends that his change of petitioners' accounting method to an accrual method is reasonable, arguing that such method is consistent with petitioners' books and records and that the accrual method of accounting reflects petitioners' income more clearly.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.