-30-
years at issue does not clearly reflect income because that
method did not reflect the proper amounts for customer cores.5
Before turning to the issues presented in this case, we note
that we have given due consideration to all of the parties'
arguments and contentions with respect to those issues, even
though we do not attempt to address each of them herein.
Consolidated's LIFO Method
For all relevant periods until the close of its taxable year
1980, Consolidated chose to report its inventories in its tax
returns on the basis of the FIFO inventory method and LCM. In
the 1980 Form 970 that it filed, Consolidated elected to apply
the LIFO inventory method as of the close of its taxable year
1980 to "Reconditioning costs and new parts inventories, not
including the cost of used core inventory" and to use the dollar-
value LIFO inventory method.6 In the 1982 Form 970 that it
5 Respondent does not object to Consolidated's method of
accounting for core supplier cores. We shall address only
Consolidated's inventory method of accounting for customer cores.
6 Sec. 1.472-8(a), Income Tax Regs., provides in pertinent
part:
Any taxpayer may elect to determine the cost of his
LIFO inventories under the so-called "dollar-value"
LIFO method, provided such method is used consistently
and clearly reflects the income of the taxpayer in
accordance with the rules of this section. The dollar-
value method of valuing LIFO inventories is a method of
determining cost by using "base-year" cost expressed in
terms of total dollars rather than the quantity and
price of specific goods as the unit of measurement.
Under such method the goods contained in the inventory
(continued...)
Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 NextLast modified: May 25, 2011