SECTION 7. RECORD KEEPING

Section 6001 provides that every person liable for any tax imposed by the Code, or for the collection thereof, must keep such records, render such statements, make such returns, and comply with such rules and regulations as the Secretary may from time to time prescribe. The books or records required by § 6001 must be kept at all times available for inspection by authorized internal revenue officers or employees, and must be retained so long as the contents thereof may become material in the administration of any internal revenue law. Section 1.6001–1(e). In order

a taxpayer is a “heavy equipment dealer” only if it sells new heavy equipment under an agreement with one or more heavy equipment manufacturers or distributors and earns a majority of its revenue from the sale, or sale and lease, of new heavy equipment. Heavy equipment is defined as those items that fall within the Bureau of Labor Statistics Producer Price Indices WPU111 and WPU112.

.06 Heavy Equipment Parts Inventory . For purposes of this revenue procedure, “heavy equipment parts inventory” means goods held as inventory that are, or could be, used to replace original parts on heavy equipment, are necessary for the proper operation of that heavy equipment, and are not accessories.

.07 Future Reconsideration of the Use of Replacement Cost . If the Service later determines that circumstances have changed so that the replacement cost of heavy equipment parts no longer approximates the actual cost of heavy equipment parts, the Service may reconsider the safe harbor replacement cost method provided in this section 4 of this revenue procedure and may modify or revoke the method for future taxable years.