Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 38

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               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. * * *                                     





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