Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 41

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          that satisfy the requirements of section 471, to mean in the case           
          of inventories for goods in process and for finished goods--                
               (1) the cost of raw materials and supplies entering                    
               into or consumed in connection with the product,                       
               (2) expenditures for direct labor, and (3) indirect                    
               production costs incident to and necessary for the                     
               production of the particular article * * *                             
          The foregoing definition of the term "cost" does not transform              
          the latter two items in that definition (viz, in the instant case           
          labor and overhead) into goods subject to inventory as to which a           
          taxpayer may elect the LIFO inventory method under section 472.             
          In other words, just because the costs of the labor and overhead            
          involved here are two of the three basic elements of cost that              
          were reflected in Consolidated’s inventories for goods in process           
          and for finished goods, see sec. 1.471-4(a), Income Tax Regs.,              
          does not convert labor and overhead into goods themselves as to             
          which Consolidated could have elected the LIFO inventory method             
          under section 472.                                                          
               Nor does the fact that the cost of Consolidated’s new parts,           
          one of the two raw materials used by Consolidated in its                    
          remanufacturing business, is a third basic element of cost that             
          also was reflected in Consolidated’s inventories for goods in               
          process and for finished goods, see id., mean that its labor and            
          overhead, when combined with its new parts, become goods as to              
          which Consolidated could have elected the LIFO inventory method             
          under section 472.  As stated above, the goods produced by                  
          Consolidated are remanufactured automobile parts or a type or               




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