Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 51

                                        -51-                                          
               To illustrate, pursuant to the rules for establishing                  
          natural business unit pools, a pool is to consist of all items              
          entering into the entire inventory investment for a natural                 
          business unit of a business enterprise,17 unless the taxpayer               
          elects to use the multiple pooling method provided in section               
          1.472-8(b)(3), Income Tax Regs.  If a business enterprise is                
          comprised of only one natural business unit, one pool is to be              
          used for "all of its inventories, including raw materials, goods            
          in process, and finished goods".  Sec. 1.472-8(b)(1), Income Tax            
          Regs.  If a business enterprise is composed of more than one                
          natural business unit, more than one pool is required.  Id.                 
               To illustrate further, a taxpayer may elect to establish               
          multiple pools for inventory items that are not within a natural            
          business unit as to which the taxpayer has adopted the natural              
          business unit method of pooling as provided in section 1.472-               
          8(b)(1), Income Tax Regs.  Sec. 1.472-8(b)(3)(i)(a), Income Tax             
          Regs.  In the event of such an election, each such pool is                  
          ordinarily to consist of a group of inventory items that are                
          substantially similar, which is to be determined based on all the           


               17  Whether an enterprise consists of more than one natural            
          business unit is a matter of fact to be determined from all the             
          circumstances.  Sec. 1.472-8(b)(2)(i), Income Tax Regs.  In the             
          case of a manufacturer, like Consolidated, a natural business               
          unit "ordinarily consists of the entire productive activity of              
          the enterprise within one product line or within two or more                
          related product lines including * * * the obtaining of materials,           
          the processing of materials, and the selling of manufactured                
          * * * goods."  Id.                                                          




Page:  Previous  41  42  43  44  45  46  47  48  49  50  51  52  53  54  55  56  57  58  59  60  Next

Last modified: May 25, 2011