-38- goods (new parts and reconditioning costs) on LIFO, and a portion of the goods (cores) on FIFO. A permissible variance to the inclusion of the total goods in LIFO is provided by Treas. Reg. � 1.472- 1(c) which allows the LIFO election to be restricted to raw materials. * * * * * * * * * * * * * Consolidated has fashioned a method of accounting that factors out inflationary price increases for part of a particular good (labor, overhead and a secondary raw material--new parts) and takes into account inflation and changes in market value for the remaining portion of the goods (the principal raw material--the core). This is inconsistent with the plain language of � 472 and the purpose of the LIFO method. A taxpayer must decide in toto for a type or class of goods whe- ther it will use either the LIFO method to currently deduct inflationary price increases or the LCM method to currently deduct decreases in the market value of production costs. A taxpayer is not permitted to use a hybrid of these two methods for a single type or class of goods. In support of respondent’s position, respondent points, inter alia, to section 472(a) and section 1.472-1(a), Income Tax Regs. Section 472(a) provides in pertinent part: "A taxpayer may use the [LIFO inventory] method * * * in inventorying goods specified in an application to use such method". Section 1.472- 1(a), Income Tax Regs., elaborates on section 472(a), in pertinent part, as follows: Any taxpayer permitted or required to take inventories pursuant to the provisions of section 471, and pursuant to the provisions of �� 1.471-1 to 1.471-9, inclusive, may elect with respect to those goods specified in his application and properly subject to inventory to compute his opening and closing inventories in accordance with the method provided by section 472, this section, and � 1.472-2. * * *Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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