-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
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