-53-
The LIFO inventory method is not dependent upon the
character of the business in which the taxpayer is
engaged or upon the identity or want of identity
through commingling of any of the goods on hand, and
may be adopted by the taxpayer as of the close of any
taxable year.
The foregoing regulation does not permit a taxpayer flexibility
to elect a LIFO inventory method that is contrary to the
requirements of section 472 and the regulations thereunder.
Section 1.472-1(l), Income Tax Regs., provides:
If a taxpayer uses consistently the so-called "dollar-
value" method of pricing inventories, or any other
method of computation established to the satisfaction
of the Commissioner as reasonably adaptable to the
purpose and intent of section 472 and this section, and
if such taxpayer elects under section 472 to use the
LIFO inventory method authorized by such section, the
taxpayer's opening and closing inventories shall be
determined under section 472 by the use of the
appropriate adaptation. * * *
Petitioner directs us to the reference in the foregoing
regulation to "any other method of computation". Consolidated
elected the dollar-value LIFO inventory method in the 1980 Form
970 and the 1982 Form 970. It did not elect "any other method of
computation" referred to in the foregoing regulation. Even if
Consolidated had used any such other method, it would have been
required to establish to the satisfaction of respondent that such
other method is "reasonably adaptable to the purpose and intent
of section 472 and" the regulations thereunder. Consolidated has
failed to make such a showing to respondent or to the Court.
Petitioner also argues that section 1.472-8(b)(3)(i)(d),
Income Tax Regs., supports its position that Consolidated should
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