Product sellers deduct inventory one of two ways in 2026, and which one you use turns on a single number: your average annual gross receipts. If they are at or below the $32 million small-business threshold (IRC §448(c), inflation-indexed for 2026), you can skip formal inventory accounting under §471(c) and deduct inventory the way your books already do, or treat it as non-incidental materials and supplies. Above $32 million, you must capitalize inventory and deduct it as cost of goods sold (COGS) only when the item actually sells. Picking the right method is often worth tens of thousands of dollars in accelerated deductions and cash flow.
Key takeaways:
2026 small-business threshold: $32,000,000 average annual gross receipts over the prior 3 years (IRC §448(c); it was $30M in 2024 and $31M in 2025). At or under it, §471(c) exempts you from the general inventory rules and from UNICAP (§263A).
Two simplified §471(c) options: (1) follow your books-and-records method, which for a cash-basis seller can deduct inventory when paid; (2) treat inventory as non-incidental materials and supplies (NIMS), deductible when the item is provided to the customer or when paid, whichever is later.
COGS timing (over $32M, or if you keep formal inventory records): beginning inventory + purchases − ending inventory, deducted only for goods actually sold, reported on Schedule C Part III (Lines 35–42) or Form 1125-A.
Valuation methods: FIFO, LIFO (needs Form 970 and follows the LIFO conformity rule), average cost, or specific identification.
Changing methods requires IRS Form 3115 and a §481(a) adjustment.
Two simplified inventory options became available under §471(c)
UNICAP rules don't apply to qualifying small businesses
Earlier deductions = better cash flow
The size test is the §448(c) gross receipts threshold, and it is indexed for inflation each year: $30 million (2024), $31 million (2025), and $32 million (2026). For a 2026 tax year, "small business taxpayer" means average annual gross receipts of $32,000,000 or less over the 3 prior tax years.
Legal Citation:IRC § 471(c) - Exemption from inventory accounting for certain small business taxpayers; threshold set by IRC § 448(c) and indexed by Rev. Proc. 2025-32 for 2026
Average annual gross receipts = (Year 1 receipts + Year 2 receipts + Year 3 receipts) ÷ 3
Example:
Year
Gross receipts
2024
$22,000,000
2025
$28,000,000
2026
$31,000,000
Average: ($22M + $28M + $31M) ÷ 3 = $27,000,000
Result: Under the $32M threshold, so this business is eligible for the simplified inventory methods.
Important: You use the average over 3 years, not just the current year. So even if a single year exceeds $32M, you still qualify if the 3-year average is at or under $32M.
Enter your three-year average gross receipts and how you keep your books — the $32 million test decides whether formal inventory accounting is optional.
$
(Year 1 + Year 2 + Year 3) ÷ 3, gross sales before returns and COGS.
You qualify for §471(c): books-conformity or NIMS, no UNICAP. Under the small-business exemption you can follow your own books — if they expense inventory when purchased, you deduct it when you pay for it (books-conformity), as long as you don't keep inventory records for creditors or cost allocation. NIMS is the alternative.
2026 threshold $32,000,000 average annual gross receipts over the three prior tax years (IRC §448(c), Rev. Proc. 2025-32), per this guide. Average all three years — one big year doesn't disqualify you. Changing methods requires Form 3115.
If your business is at or under the $32M threshold and uses the cash method of accounting, §471(c) lets you follow the inventory treatment in your own books and records. When those books expense inventory when purchased, you deduct it when you pay for it, as long as you don't maintain inventory records for cost allocation or creditor reporting. This is the non-financial-statement (non-AFS) books-conformity method under IRC §471(c)(1)(B)(ii).
Requirements:
Gross receipts at or under $32M (3-year average)
Use cash method of accounting
Your books and records expense inventory when purchased and don't:
Allocate costs to ending inventory
Calculate COGS
Report inventory value to banks/creditors
What you CAN do:
✅ Track inventory for reordering purposes
✅ Use point-of-sale systems for sales tracking
✅ Monitor stock levels for operations
What you CANNOT do (if you want immediate deduction):
❌ Take physical inventory counts for financial reporting
❌ Allocate costs between sold and unsold inventory
❌ Report inventory value to lenders
❌ Calculate year-end inventory value in your books
Legal Citation:IRC § 471(c)(1)(B)(ii) and Reg. § 1.471-1(b) - inventory method conforming to a small business taxpayer's books and records
Businesses at or under the $32M threshold can elect to treat inventory as non-incidental materials and supplies (NIMS) under §471(c). Under the final regulations (T.D. 9942), NIMS inventory is recovered through cost of goods sold in the year the item is provided to the customer (when it sells) or the year you pay for or incur the cost, whichever is later.
Common misconception: NIMS does not let a manufacturer deduct raw materials the moment they move into production. The IRS confirmed in the final small business taxpayer regulations that raw materials converted to work-in-process or finished goods, but not yet sold, are not "used or consumed" for this purpose. So NIMS timing lands close to traditional COGS.
The real advantage is simpler recordkeeping, not earlier timing:
Only direct material cost (or purchase cost for resale) is included in the NIMS amount
Direct labor and indirect overhead are deducted in the year paid or incurred, not capitalized into inventory
UNICAP (§263A) does not apply
Who benefits most:
Manufacturers and custom fabricators who want out of UNICAP and full inventory accounting
Businesses with significant direct labor and overhead they can now deduct currently
Legal Citation:IRC § 471(c)(1)(B)(i) and Reg. § 1.471-1(b) - non-incidental materials and supplies method
Scenario: A custom furniture manufacturer with $22M in gross receipts buys $800,000 in lumber and hardware in December 2026, moves it into production in January 2027, and sells the finished furniture in March 2027.
Under the NIMS method, the $800,000 direct material cost is recovered through COGS in March 2027, when the furniture is provided to the customer (or when paid, if that is later). The timing matches traditional COGS. What changes is that the manufacturer deducts its direct labor and factory overhead in the year incurred and skips UNICAP, which simplifies the books and accelerates those non-material deductions.
When you maintain traditional inventory, you must choose an accounting method to value your ending inventory. This choice affects your COGS and taxable income.
Choosing an inventory method is a tax decision, but getting the numbers right is bookkeeping. Jupid connects your bank and categorizes every purchase at 95.9% accuracy, so inventory buys, freight, and supplies are tagged and ready when you compute cost of goods sold. Instead of digging through spreadsheets at year-end, ask your AI accountant in WhatsApp or iMessage "how much did I spend on inventory this quarter?" or "which purchases count toward COGS?" and get an answer with the underlying transactions linked. That keeps your beginning inventory, purchases, and ending inventory reconciled all year, whether you deduct under the §471(c) small business rules or traditional COGS.
Inventory tax deductions are one of the most overlooked opportunities for product-based businesses. Since the 2018 tax law changes, small business taxpayers at or under the $32M gross receipts threshold can drop formal inventory accounting under §471(c), which for a cash-method seller can free up cash flow that used to be tied up in unsold inventory.
The key is understanding your options:
Books-conformity method for cash-method sellers (deduct inventory when paid)
Non-incidental materials & supplies (deduct when the item sells or when paid, whichever is later; no UNICAP)
Traditional COGS with FIFO, LIFO, or Average Cost
Your choice depends on:
Your gross receipts (above or below $32M)
Whether you manufacture or resell goods
Your need for financial statement reporting
Your cash flow priorities
Current economic conditions (inflation/deflation)
Remember: If you're at or under $32M and still using the accrual method with traditional COGS, you may be paying tax on inventory you haven't sold yet. A cash-method, books-conformity election can be one of the most valuable planning moves you make this year, but it requires Form 3115 and a §481(a) adjustment, so run it past a tax professional first.
Disclaimer
This article provides general information about tax deductions and should not be considered tax advice. Tax laws change frequently, and individual circumstances vary significantly. Inventory accounting method changes require careful analysis and IRS Form 3115 filing. For advice specific to your situation, consult with a qualified tax professional.
Fintech CEO with 10+ years building accounting and financial technology products. Previously co-founded and scaled an AI-powered accounting platform to $30M revenue and 100K+ business users, achieving 30,000 customers per accountant through automation — recognized by CNBC as a top fintech company. Holds a Master's in Management Information Systems. At Jupid, he leads the development of AI-native bookkeeping, tax, and compliance tools designed for freelancers and small business owners.