-43-
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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