IRS OKs Rolling Average

BY ROBERT BLOOM

The IRS now considers a rolling-average method of inventory costing used for financial statements to be acceptable as well for income tax reporting, assuming the taxpayer satisfies one of two safe harbors. Additionally, the IRS furnishes automatic consent to change to a rolling-average method.

Companies in various industries view the rolling-average method to be a reliable approach to estimation of inventory and cost of goods sold and therefore use it for financial reporting. Revenue Procedure 2008-43, issued in June, states that the IRS may accept this method for income tax reporting, assuming it is reliable for the taxpayer in question. The method might not accurately reflect the taxpayer’s income, however, where inventory is held for several years or its costs are unstable. Additionally, if the taxpayer is not using the rolling average for accounting, this method may not be suitable for reflecting taxable income.

Accordingly, the rolling-average method will be deemed to accurately reflect income where (1) the taxpayer recalculates the rolling average every time it purchases or produces an additional unit of an item, or on a regular basis of at least once a month, and (2) the taxpayer meets either of two tests: (a) the ending inventory cost under the rolling-average method does not vary by more than 1% from its cost under the first-in, first-out (FIFO) or other specific identification method used, or (b) the entire inventory of the taxpayer turns over at least four times a year. The number of times that the total inventory of the taxpayer turns over (known as the inventory turnover ratio) is the cost of goods sold divided by the average of the beginning and ending inventory.

Revenue Procedure 2008-43 is effective for tax years ending on or after Dec. 31, 2007. The IRS will not raise an issue over the application of rolling average on federal tax returns filed before June 25, 2008, that follow this procedure, and it will not pursue the issue further in examinations or appeals of such returns.

Revenue Ruling 71-234, 1971-1 CB 148, and Revenue Ruling 77-480, 1977-2 CB 186, are modified to allow the taxpayer to apply the rolling-average method to inventories in accordance with Revenue Procedure 2008-43. Revenue Procedure 2002-9, 2002-1 CB 327, is modified as well to incorporate the automatic change under the new procedure.

n Revenue Procedure 2008-43

By Robert Bloom, Ph.D., professor and Mulwick Scholar in Accountancy, John Carroll University, University Heights, Ohio.

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