Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 35

                                        -35-                                          
               In 1944, section 29.22(d)-1 of Regulations 111 was amended             
          to add in pertinent part the following language:                            
                    A manufacturer or processor who has adopted the                   
               elective [LIFO] inventory method as to a class of goods                
               may elect to have such method apply to the raw                         
               materials only (including those included in goods in                   
               process and in finished goods) expressed in terms of                   
               appropriate units. * * *                                               
                         *    *    *    *    *    *    *                              
                    This election may also apply to any one raw                       
               material, when two or more raw materials enter into the                
               composition of the finished product * * *                              
          9 Fed. Reg. 12336, 12337 (Oct. 11, 1944).  (We shall refer to the           
          amendment in 1944 to section 29.22(d)-1 of Regulations 111 as the           
          1944 amendment to section 29.22(d)-1 of Regulations 111.)                   
               Section 22(d)(1) through (3) of the 1939 Code as amended was           
          reenacted with changes not pertinent here as section 472(a) and             
          (b) of the 1954 Code, ch. 736, sec. 472(a) and (b), 68A Stat.               
          159, and the latter section was reenacted with no changes as                
          section 472(a) and (b) of the 1986 Code, see Tax Reform Act of              
          1986, Pub. L. 99-514, sec. 2, 100 Stat. 2095.  Sections 29.22(d)-           
          1 and -2 of Regulations 111, including the 1944 amendment to                
          section 29.22(d)-1 of Regulations 111, were repromulgated with              
          changes not pertinent here as regulations under section 472.                
               With this history as background, we shall address the                  
          disagreement between the parties over whether Consolidated's LIFO           
          method contravenes the requirements of section 472 and the                  
          regulations thereunder and therefore does not clearly reflect               





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