Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 3

                                         -3-                                          
                              Adjustments to Ordinary,                                
                              Distributable Net, or                                   
                    Year      Taxable Income                                          
                    1990           $3,730,862                                         
                    1991           123,596                                            
               The issues remaining for decision are:                                 
               (1) Did respondent abuse respondent's discretion in                    
          determining that Consolidated's method of reporting certain raw             
          materials, labor, and overhead on the LIFO inventory method and             
          certain other raw materials on the FIFO inventory method does not           
          clearly reflect income because it contravenes the requirements of           
          section 472 and the regulations thereunder and that therefore               
          Consolidated's election to use that method should be terminated?            
          We hold that respondent did not.                                            
               (2) Did respondent abuse respondent's discretion in                    
          determining that Consolidated's method of valuing certain raw               
          materials does not clearly reflect income because it did not                
          reflect the proper amounts for those raw materials under the FIFO           
          inventory method and the LCM basis of valuation permitted by                
          section 471?  We hold that respondent did not.                              
                                  FINDINGS OF FACT2                                   
               Most of the facts have been stipulated and are so found.               



               2  Unless otherwise indicated, our Findings of Fact and                
          Opinion pertain to 1990 and 1991, the years at issue.                       







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