Internal Revenue Code · 26 U.S.C.

§ 472. Last-in, first-out inventories

In force Text current through Public Law 119-121 (October 9, 2026) release point 119-121

Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).

Cite as 26 U.S.C. § 472

At a glance

Read from the text, the source credit and the official notes. Not part of the law.

Status: In force
Enacted: October 4, 1976 by Pub. L. 94–455
Last amended: July 18, 1984 by Pub. L. 98–369
Amendments: 2 dated changes in the source credit
Length: 7 subsections · 739 words · about 3 min to read
Defines: 1 term
Cross-references: cites 2; cited by 4 Code sections and 14 other regulations
Regulations: 8 issued under this section

¶(a) Authorization

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) Method applicable 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) Condition 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) 3-year averaging for increases in inventory value

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) Subsequent inventories 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.

If paragraph (1) or (2) of this subsection applies, the change to, and the use of, the different 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.

¶(f) Use of government price indexes in pricing inventory

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) Conformity rules applied on controlled group basis

¶(1) In general

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) Group of financially related corporations For purposes of paragraph (1), the term “” 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.

(Aug. 16, 1954, ch. 736, 68A Stat. 159; Pub. L. 94–455, title XIX, §§ 1901(b)(36)(A), 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1802, 1834; Pub. L. 97–34, title II, §§ 235, 236(a), Aug. 13, 1981, 95 Stat. 252; Pub. L. 98–369, div. A, title I, § 95(a), July 18, 1984, 98 Stat. 616.)

Terms defined here

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group of financially related corporations § 472(g)(2)

Regulations under this section

Treasury regulations (26 CFR) issued under § 472

Cross-references

Computed from the citations in the text of Title 26 and 26 CFR.

This section cites 2 other sections

Cited by 4 Code sections

Cited in 14 regulations not issued under it

Amendment history

From the source credit and the official notes, newest first.

July 18, 1984Amended by Pub. L. 98–369Parts changed in 1984: (g)
August 13, 1981Amended by Pub. L. 97–34Parts changed in 1981: (d) (f)
October 4, 1976Enacted by Pub. L. 94–455Parts changed in 1976: (a) (f)

Where it sits in the Code

Nearby sections

§ 471 General rule for inventories
§ 472 Last-in, first-out inventories
§ 473 Qualified liquidations of LIFO inventories
§ 474 Simplified dollar-value LIFO method for certain small businesses
§ 475 Mark to market accounting method for dealers in securities

Official notes

Show the Law Revision Counsel's notes (amendments, effective dates)

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.

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 Amendment

Amendment 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.