Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 29

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                         (2) Inventory them at cost; and                              
                         (3) Treat those included in the opening                      
                    inventory of the taxable year in which such                       
                    method is first used as having been acquired                      
                    at the same time and determine their cost by                      
                    the average cost method.                                          
               Sections 446 and 471 and the regulations thereunder vest the           
          Commissioner of Internal Revenue (Commissioner) with wide                   
          discretion in determining whether a method of inventory                     
          accounting should be disallowed because it does not clearly                 
          reflect income.  Thor Power Tool Co. v. Commissioner, 439 U.S.              
          522, 532-533 (1979); Hamilton Indus., Inc. v. Commissioner, 97              
          T.C. 120, 128 (1991).  The Commissioner's interpretation of the             
          clear-reflection standard under sections 446 and 471 may not be             
          disturbed unless it is clearly unlawful or plainly arbitrary.               
          Thor Power Tool Co. v. Commissioner, supra; Hamilton Indus., Inc.           
          v. Commissioner, supra at 129.  The Commissioner's discretion               
          under sections 446 and 471 is not unbridled, however.  Thor Power           
          Tool Co. v. Commissioner, supra at 533; Hamilton Indus., Inc. v.            
          Commissioner, supra at 128.  We must decide whether respondent              
          abused respondent's discretion in determining (1)(a) that                   
          Consolidated's LIFO method for 1990 and 1991 does not clearly               
          reflect income because that method pertained only to new parts,             
          labor, and overhead, and not also to customer cores, and (b) that           
          therefore Consolidated's election to use that method should be              
          terminated and (2) that Consolidated's FIFO-LCM method for the              






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