Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 27

                                        -27-                                          
          Respondent's Determinations                                                 
               Respondent mailed notices of final S corporation                       
          administrative adjustment (notices) for 1990 and 1991,                      
          respectively, to Merl Philip Long, grantor and trustee of the               
          M.P. Long Living Trust, the tax matters person.  Respondent                 
          determined in the notices that Consolidated improperly excluded             
          customer cores from the calculation of its inventories under                
          Consolidated's LIFO method for each of those years and that,                
          consequently, Consolidated's LIFO election should be terminated.            
          Respondent also determined in the notices that Consolidated did             
          not reflect the proper amounts for customer cores in its                    
          inventories under Consolidated's FIFO-LCM method for each of                
          those years.4                                                               
                                       OPINION                                        
               This case presents several inventory accounting issues that            
          implicate sections 446, 471, and 472.  Section 446 provides in              
          pertinent part:                                                             
                    (a) General Rule.--Taxable income shall be                        
               computed under the method of accounting on the basis of                
               which the taxpayer regularly computes his income in                    
               keeping his books.                                                     
                    (b) Exceptions.--If no method of accounting has                   
               been regularly used by the taxpayer, or if the method                  
               used does not clearly reflect income, the computation                  
               of taxable income shall be made under such method as,                  
               in the opinion of the Secretary, does clearly reflect                  
               income.                                                                


               4  Petitioner conceded the remaining determination in the              
          notice for 1990.                                                            




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