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Title 26 — Internal Revenue CodeRelease 119-73not60

§472 Last-in, First-out Inventories

Title 26 › Subtitle Subtitle A— Income Taxes › Chapter 1— NORMAL TAXES AND SURTAXES › Subchapter E— Accounting Periods and Methods of Accounting › Part II— METHODS OF ACCOUNTING › Subpart D— Inventories › § 472

Last updated Apr 5, 2026|Official source

Summary

You can use the last-in, first-out (LIFO) way of counting inventory if you file an application with the Secretary in the time and manner they require and follow rules that make your income clear. When using this method for the goods named in your application, count year-end stock as coming first from the opening inventory (in its buy order) and then from items bought during the year. Value the inventory at cost. For the opening inventory in the first year you use LIFO, treat those items as if they were all bought at the same time and figure their cost by the average-cost method. You must show the Secretary that you did not use any other counting method for reports to owners or for credit purposes for the first year you switch. Value the beginning inventory at cost and spread any change in inventory value evenly over the next 3 taxable years starting with the first LIFO year. Once you use LIFO you must keep using it unless the Secretary allows a change or forces one because you used a different procedure for later reports. The Secretary may allow published government indexes to be used. Closely related corporations are treated as one taxpayer for some of these rules; that group is defined by using a 50 percent test instead of 80 percent, or by groups that combine financial statements.

Full Legal Text

Title 26, §472

Internal Revenue Code — Source: USLM XML via OLRC

(a)A taxpayer may use the method provided in subsection (b) (whether or not such method has been prescribed under section 471) in inventorying goods specified in an application to use such method filed at such time and in such manner as the Secretary may prescribe. The change to, and the use of, such method shall be in accordance with such regulations as the Secretary may prescribe as necessary in order that the use of such method may clearly reflect income.
(b)In inventorying goods specified in the application described in subsection (a), the taxpayer shall:
(1)Treat those remaining on hand at the close of the taxable year as being: First, those included in the opening inventory of the taxable year (in the order of acquisition) to the extent thereof; and second, those acquired in the taxable year;
(2)Inventory them at cost; and
(3)Treat those included in the opening inventory of the taxable year in which such method is first used as having been acquired at the same time and determine their cost by the average cost method.
(c)Subsection (a) shall apply only if the taxpayer establishes to the satisfaction of the Secretary that the taxpayer has used no procedure other than that specified in paragraphs (1) and (3) of subsection (b) in inventorying such goods to ascertain the income, profit, or loss of the first taxable year for which the method described in subsection (b) is to be used, for the purpose of a report or statement covering such taxable year—
(1)to shareholders, partners, or other proprietors, or to beneficiaries, or
(2)for credit purposes.
(d)The beginning inventory for the first taxable year for which the method described in subsection (b) is used shall be valued at cost. Any change in the inventory amount resulting from the application of the preceding sentence shall be taken into account ratably in each of the 3 taxable years beginning with the first taxable year for which the method described in subsection (b) is first used.
(e)If a taxpayer, having complied with subsection (a), uses the method described in subsection (b) for any taxable year, then such method shall be used in all subsequent taxable years unless—
(1)with the approval of the Secretary a change to a different method is authorized; or,
(2)the Secretary determines that the taxpayer has used for any such subsequent taxable year some procedure other than that specified in paragraph (1) of subsection (b) in inventorying the goods specified in the application to ascertain the income, profit, or loss of such subsequent taxable year for the purpose of a report or statement covering such taxable year (A) to shareholders, partners, or other proprietors, or beneficiaries, or (B) for credit purposes; and requires a change to a method different from that prescribed in subsection (b) beginning with such subsequent taxable year or any taxable year thereafter.
(f)The Secretary shall prescribe regulations permitting the use of suitable published governmental indexes in such manner and circumstances as determined by the Secretary for purposes of the method described in subsection (b).
(g)(1)Except as otherwise provided in regulations, all members of the same group of financially related corporations shall be treated as 1 taxpayer for purposes of subsections (c) and (e)(2).
(2)For purposes of paragraph (1), the term “group of financially related corporations” means—
(A)any affiliated group as defined in section 1504 determined by substituting “50 percent” for “80 percent” each place it appears in section 1504(a) and without regard to section 1504(b), and
(B)any other group of corporations which consolidate or combine for purposes of financial statements.

Legislative History

Notes & Related Subsidiaries

Editorial Notes

Amendments

1984—Subsec. (g). Pub. L. 98–369 added subsec. (g). 1981—Subsec. (d). Pub. L. 97–34, § 236(a), substituted “3-year averaging for increases in inventory value” for “Preceding closing inventory” in heading, substituted first sentence reading “The beginning inventory for the first taxable year for which the method described in subsection (b) is used shall be valued at cost.” for “In determining income for the taxable year preceding the taxable year for which the method described in subsection (b) is first used, the closing inventory of such preceding year of the goods specified in the application referred to in subsection (a) shall be at cost.” and inserted “Any change in the inventory amount resulting from the application of the preceding sentence shall be taken into account ratably in each of the 3 taxable years beginning with the first taxable year for which the method described in subsection (b) is first used.” Subsec. (f). Pub. L. 97–34, § 235, added subsec. (f). 1976—Subsecs. (a), (c), (e). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary” wherever appearing. Subsec. (f). Pub. L. 94–455, § 1901(b)(36)(A), struck out subsec. (f) which provided for a cross reference relating to involuntary liquidation and replacement of LIFO inventories.

Statutory Notes and Related Subsidiaries

Effective Date

of 1984 Amendment Pub. L. 98–369, div. A, title I, § 95(b),
July 18, 1984, 98 Stat. 616, provided that: “The amendment made by subsection (a) [amending this section] shall apply to taxable years beginning after the date of the enactment of this Act [
July 18, 1984].”

Effective Date

of 1981 Amendment Pub. L. 97–34, title II, § 236(b), Aug. 13, 1981, 95 Stat. 252, provided that: “The amendment made by subsection (a) [amending this section] shall apply to taxable years beginning after December 31, 1981.”

Effective Date

of 1976 AmendmentAmendment by section 1901(b)(36)(A) of Pub. L. 94–455 effective for taxable years beginning after Dec. 31, 1976, see section 1901(d) of Pub. L. 94–455, set out as a note under section 2 of this title.

Reference

Citations & Metadata

Citation

26 U.S.C. § 472

Title 26 — Internal Revenue Code

Last Updated

Apr 5, 2026

Release point: 119-73not60