-45- section 29.22(d)-1 of Regulations 111, provides in pertinent part: (c) A manufacturer or processor who has adopted the LIFO inventory method as to a class of goods may elect to have such method apply to the raw materials only (including those included in goods in process and in finished goods) expressed in terms of appropriate units. If such method is adopted, the adjustments are confined to costs of the raw material in the inventory and the cost of the raw material in goods in process and in finished goods produced by such manufacturer or processor and reflected in the inventory. * * * Section 1.472-1(j), Income Tax Regs., as did the 1944 amendment to section 29.22(d)-1 of Regulations 111, states that the election under section 1.472-1(c), Income Tax Regs., may "apply to any one raw material, when two or more raw materials enter into the composition of the finished product". We disagree with petitioner’s assertions that, under section 1.472-1(c), Income Tax Regs., a taxpayer’s LIFO election is limited to the cost of raw materials, including the cost of the raw material content of work-in-progress and finished goods. * * * [A] taxpayer using the raw material content [LIFO inventory] method elects to value the cost of raw materials (including the cost of raw materials incorporated into work-in-progress and finished goods) using the LIFO convention, not the raw materials themselves. * * *[12] [Emphasis added.] 12 Petitioner also contends that, because the examples in sec. 1.472-1(c), Income Tax Regs., illustrate the manner in which a raw material may be accounted for on the raw material content LIFO inventory method and labor and overhead on the FIFO inventory method, It is not logical to conclude that when LIFO is elected for one raw material, together with labor and overhead, (continued...)Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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