Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 32

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          accounting, the FIFO inventory method, and the LIFO inventory               
          method.  The use of inventories was first required by the Revenue           
          Act of 1918 (1918 Act), ch. 18, sec. 203, 40 Stat. 1060,                    
          whenever, in the opinion of the Commissioner, such use was                  
          necessary in order to determine clearly the income of any                   
          taxpayer.7  Where goods taken in inventory were so intermingled             
          that they could not be identified with specific invoices, Article           
          1582 of Regulations 45, promulgated under the 1918 Act, deemed              
          such goods to be the goods most recently purchased or produced.             
          In other words, in such circumstances, taxpayers were to use the            
          FIFO inventory method as a matter of convenience.8  See Ozark               
          Mills, Inc. v. Commissioner, 6 B.T.A. 1179, 1183-1184 (1927).               
               It was not until the Revenue Act of 1938 (1938 Act), ch.               
          289, 52 Stat. 447, that Congress first allowed certain taxpayers            
          (viz, producers and processors of certain nonferrous metals and             
          tanners) who were required to use the inventory accounting method           
          to elect the LIFO inventory method for certain goods included in            
          their inventories.  1938 Act, sec. 22(d)(1) through (3), 52 Stat.           
          459.  Effective for taxable years that began after December 31,             
          1938, producers and processors of certain nonferrous metals                 


               7  Sec. 203 of the Revenue Act of 1918, ch. 18, sec. 203, 40           
          Stat. 1060, was the original predecessor of sec. 471.                       
               8  The FIFO inventory method is expressly permitted by sec.            
          1.471-2(d), Income Tax Regs., when goods taken in inventory are             
          so intermingled that they cannot be identified with specific                
          invoices.                                                                   




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