Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 45

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          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...)           




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