-52-
facts and circumstances. Id. Pursuant to the rules for
establishing multiple pools, unprocessed raw materials which are
substantially similar are to be pooled together, and goods in
process and finished goods in the inventory are to be placed in
pools classified by major types or classes of goods.18 Sec.
1.472-8(b)(3)(i)(b) and (c), Income Tax Regs.
In the face of various provisions in section 472 and the
regulations thereunder that respondent contends, and we agree,
are contrary to Consolidated’s LIFO method, petitioner argues
that taxpayers are afforded great flexibility with respect to the
dollar-value LIFO inventory method and computational procedures
under that method. Consequently, according to petitioner,
Consolidated should be afforded great flexibility with respect to
Consolidated's LIFO method. In support of that position,
petitioner cites section 1.472-1(a), (l) and section 1.472-
8(b)(3)(i)(d), Income Tax Regs.
Section 1.472-1(a), Income Tax Regs., provides in pertinent
part:
18 The requirement in sec. 1.472-8(b)(3)(i)(b) and (c),
Income Tax Regs., that a taxpayer establish pools by major types
of materials or major classes of goods does not preclude the
establishment of a miscellaneous pool. Because a taxpayer may
elect the dollar-value LIFO inventory method with respect to all
or any designated goods in such taxpayer’s inventory, there may
be a number of such inventory items covered in the election. A
miscellaneous pool is to consist only of items that are rela-
tively insignificant in dollar value when compared to other
inventory items in the particular trade or business and that are
not properly includible as part of another pool. Sec. 1.472-
8(b)(3)(i)(d), Income Tax Regs.
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