Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 43

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          Consolidated’s inventories for goods in process and for finished            
          goods.  Nor do the labor and overhead involved here become a                
          good, let alone the entire good, of Consolidated subject to                 
          inventory when the new parts involved here are combined with                
          them.  The goods of Consolidated subject to inventory as to which           
          it was permitted by section 472(a) and the regulations thereunder           
          to elect the LIFO inventory method are the remanufactured                   
          automobile parts produced by Consolidated, a type or class of               
          those goods (e.g., remanufactured automobile engines), and, if              
          Consolidated had made the election permitted by section 1.472-              
          1(c), Income Tax Regs., which it did not, its raw material goods            
          (i.e., customer cores and/or new parts).                                    
               We conclude that section 472(a) requires a taxpayer who                
          wants to elect the LIFO inventory method (1) to make that                   
          election with respect to a good or goods, which are subject to              
          inventory and specified in a Form 970 and which could include one           
          or more raw material goods used by a manufacturer or processor              
          that will become part of the merchandise intended for sale, see             
          sec. 1.472-1(c), Income Tax Regs., and (2) to make that election            
          with respect to such entire good or goods.  That section does not           
          permit, and we do not construe it to allow, a taxpayer to make              
          such an election (1) with respect to other than such a good or              
          goods or (2) with respect to a portion thereof.  If Congress had            
          intended to permit such an election under section 472, it would             
          have so provided in that section.  It did not.                              




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