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for goods in process, and for finished goods and (b) labor and
overhead that were included in Consolidated's inventories for
goods in process and for finished goods and (2) the FIFO
inventory method for customer cores that were included in its
inventories for unprocessed customer cores, for goods in process,
and for finished goods.
Respondent contends that section 472 and the regulations
thereunder require a taxpayer who wants to elect the LIFO
inventory method (1) to make that election with respect to a good
or goods subject to inventory and specified in the application
prescribed by the Secretary of the Treasury (Secretary) for
electing that method (viz, Form 970) and (2) to make that
election with respect to such entire good or goods and not a
portion thereof.10 According to respondent,
It is critical to note that the statute and the
regulations specify that the election is to be made as
to "goods". The goods produced by Consolidated are
remanufactured automobile parts, such as remanufactured
engines. Under the general rule, if Consolidated
elected LIFO as to remanufactured automobile engines,
the LIFO election would apply to raw materials, i.e.
cores and new parts, and the reconditioning costs, i.e.
labor and overhead. However, Consolidated elected as
to only a portion of each type of good by excluding
cores. * * * For each type of goods, such as
remanufactured engines, this left a portion of the
10 Respondent concedes that a taxpayer may elect the LIFO
inventory method with respect to a type or class of goods, such
as remanufactured automobile engines, but contends that that
election must be as to the "entire good", and not a portion of a
good, within a type or class of goods. For convenience,
generally we shall refer only to a good or goods, and not to a
type or class of goods.
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