-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).Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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