Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 36

                                        -36-                                          
          income.  Consolidated’s remanufacturing business depended on a              
          supply of two raw materials: cores and new parts.  During the               
          remanufacturing process, Consolidated incurred expenditures for             
          labor and overhead and transformed those raw materials into its             
          finished goods or products (viz, remanufactured automobile                  
          parts).  Thus, cores, new parts, labor, and overhead all entered            
          into the production of those finished goods or products.                    
          Pursuant to section 1.471-1, Income Tax Regs., Consolidated                 
          maintained inventories for each of the two unprocessed raw                  
          materials that it used in its remanufacturing business, for                 
          partly finished goods, i.e., goods in process of remanufacture              
          (goods in process), and for finished remanufactured goods                   
          (finished goods).9  Virtually all of the cores included in                  
          Consolidated’s inventories were, and we shall hereinafter refer             
          to them as, customer cores.  See supra note 5.                              
               Consolidated elected in the 1980 Form 970 to use the LIFO              
          inventory method with respect to new parts, labor, and overhead,            
          but not customer cores.  Thus, under Consolidated's LIFO method,            
          Consolidated used (1) the LIFO inventory method for (a) new parts           
          that were included in its inventories for unprocessed new parts,            


               9  Although it is not altogether clear from the record, it             
          appears that Consolidated maintained separate unprocessed new               
          parts raw material inventories, unprocessed cores raw material              
          inventories, goods in process inventories, and finished goods               
          inventories in respect of the different types (e.g.,                        
          remanufactured automobile engines) of goods or products that it             
          produced (viz, remanufactured automobile parts).                            




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