Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 30

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          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...)           




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