-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.Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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