Subject: File No. 4-600
From: William Chambers, CPA

July 16, 2012

I disagree with the staff's conclusion that not allowing companies to use LIFO "is more of an issue of tax policy rather than of financial reporting." Clearly, in periods of high inflation net income is more accurately determined using LIFO. I think the staff should conduct more research in this area and review the impact on financial reporting over the past 40 years if LIFO was not allowed.

William Chambers, CPA