The use of the LIFO method in this industry is probably more common than for almost any other industry. We estimate the LIFO method usage rate at over 90% because of the consistency of inflation for supermarket merchandise over many years together with significant inventory balances (single store cost inventory balances ranging from $300,000 to $2,500,000).
Supermarket chain LIFO calculations are more complicated than those for most other industries. This has been one of our primary practice areas since our LIFO expertise and automated software is more useful to companies whose LIFO calculations are complicated. Complicated LIFO situations along with complicated IRS LIFO Regs. are much more likely to result in IRS Regs. noncompliance because of improper method and submethod elections and application of improper computational methodology. They are also more prone to computational errors when spreadsheet assisted manual calculations are used for numerous steps.
The Food Marketing Institute (FMI) provided a great deal of guidance regarding the use of the IPIC LIFO method by supermarkets in earlier years. The FMI and FMI members actually wrote the IPIC method IRS Regulations in 1982 in collaboration with the IRS as a result of FMI’s desire to develop a simpler LIFO methodology that would allow more widespread usage of the method by smaller supermarket chains. The FMI went a step further and produced a booklet in January 1983 entitled Handbook for LIFO Tax Valuations-Inventory Price Index Computation Method (IPIC) that was a practical how-to guide that was used extensively by supermarkets until 1998. This handbook included a list of the 21 different 10% method CPI categories that was the minimum number required for compliance with IRS Regs. before 1998. The FMI prior to 1998 also made service bureau LIFO calculations for a number of small companies using specialized LIFO software developed by a FMI member company because the calculations required were prone to error when made by in-house accountants without extensive LIFO experience.
The FMI is no longer a LIFO resource for its members and has not been since sometime in the 1990s and the specialized LIFO software referred to above is no longer used. The Handbook the FMI published in 1983 is also now obsolete because of the 1998 changes in the makeup of the CPI categories by the BLS and because of the mandatory method changes incorporated in the new IPIC LIFO Regs. issued in 2002.
We have succeeded the FMI in their role of providing guidance to implement and use the IPIC LIFO method for supermarkets. In 2003, we published our Guide for Planning & Implementation of the IPIC LIFO Method for Supermarket Chains which not only supersedes the 1983 FMI Handbook but provides much more comprehensive guidance. This guide includes a list of the 33 different 10% method CPI categories and 55 different 10% method PPI categories that has been the minimum number required for compliance with the revised IRS IPIC LIFO Regs. published in 2002.
We serve clients in all industries except auto dealers but we made our name serving retailers using the IPIC method. Our LIFO-PRO software is used for the tax LIFO calculations for over 60% (by dollar volume) of supermarkets in the U.S. and most of these companies use our LIFO consulting services. We sell licenses to use our LIFO-PRO software to companies or their CPAs and also provide LIFO service bureau calculations to companies or their CPAs. Our LIFO-PRO software is the only comprehensive, commercially available non-auto dealer LIFO program sold. There have been numerous spreadsheet templates created to use for IPIC LIFO calculations but these are very much prone to error because it is not possible to fully automate many aspects of the LIFO computations in a spreadsheet and even if you could, it is very difficult to secure a spreadsheet to prevent changes.
FIN 48 & IRS preparer penalty implications – Many LIFO computation shortcuts have been used in all industries including supermarkets. The most common supermarket LIFO shortcuts are: 1) not using the appropriate 10% method CPI or PPI categories (using too few categories or only a single category for each pool) and 2) incorrect 10% method math. Most non-large case IRS audit supermarkets faced little IRS scrutiny in the past because of the lack of LIFO experience possessed by most IRS field agents and this resulted in relatively few IRS LIFO audit adjustments. These companies and their CPAs have played “IRS audit roulette” because of the low level of LIFO IRS scrutiny.
The LIFO IRS Regs. compliance standard has been drastically raised by these new pronouncements. The numerous LIFO shortcuts (to the IRS Regs. requirements) used are all “undisclosed positions taken” that clearly are not “more likely than not” to be sustained on their merits and therefore practitioners may not sign tax returns for these taxpayers. The likelihood of IRS audit or audit adjustment are not factors to be considered in the application of this rule; only whether the CPA has knowledge of IRS Regs. noncompliance is pertinent. FIN 48 requires valuation reserves to be established for IRS Regs. noncompliance in some cases.
Use of PPI rather than CPI indexes – Many larger supermarkets chains, as well as some smaller ones, use PPI rather than CPI indexes because there has been substantially higher inflation for PPI since the early 2000s. More-detailed breakdowns are required by the IRS Regulations when PPI indexes are used. We have helped a number of our clients change methods to switch from using CPI to PPI indexes. Some non-publicly traded supermarkets use CPI for book LIFO and PPI for tax LIFO. We have written a guide addressing the steps necessary to make this change. The guide includes a list of 55 different PPI LIFO count codes necessary to comply with the IRS’s rules pertaining to the 10% Method. Contact LIFO-PRO at (402)-330-8573 or at lifopro@lifopro.com for more information on the topic of Special Challenges for Supermarkets on LIFO.
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