-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.Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
Last modified: May 25, 2011