Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 37

                                        -37-                                          
          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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