-61-
LIFO method" when it filed the 1980 Form 970 and the 1982 Form
970.23
We now turn to section 1.472-3(c), Income Tax Regs., on
which petitioner relies. That regulation provides:
As a condition to the taxpayer's use of the LIFO
inventory method, the Commissioner may require that the
method be used with respect to goods other than those
specified in the taxpayer's statement of election if,
in the opinion of the Commissioner, the use of such
method with respect to such other goods is essential to
a clear reflection of income.
Petitioner contends that in the instant case the foregoing
regulation "does not authorize Respondent to terminate a
taxpayer's LIFO election". Petitioner's reliance on section
1.472-3(c), Income Tax Regs., is misplaced. That regulation
authorizes respondent to require a taxpayer who has elected the
LIFO inventory method with respect to an entire good or goods
subject to inventory and specified in a Form 970 to apply the
LIFO inventory method to any other such good or goods but not
specified in that form. In the present case, respondent is not
seeking to require Consolidated, which did not elect the raw
material content LIFO inventory method, to apply the LIFO
inventory method to a good or goods subject to inventory but not
specified in the 1980 Form 970 and the 1982 Form 970. Conse-
23 We reject the suggestion of petitioner that sec. 3.01(b)
of Rev. Proc. 79-23, supra at 564, applies only to the procedural
requirements for electing the LIFO inventory method. See Rev.
Proc. 76-28, 1976-2 C.B. 645.
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