-66- over such cost and market that Consolidated credited to each customer account receivable are deductible expenses under section 162. In support of respondent's position that Consolidated's FIFO-LCM method does not clearly reflect income, respondent contends that Consolidated acquired customer cores in purchase, and not exchange, transactions and that therefore the cost and the market for those cores for purposes of section 471 are to be determined by reference to the invoice prices that were shown on the customer core sales invoices. According to respondent, those invoice prices are the amounts (viz, the core credit amounts) that Consolidated credited to each customer account receivable and that were shown on those invoices under the column headed "Cores--Price Each".25 Respondent further asserts that even if the Court were to find that the transactions by which Consolidated acquired customer cores were exchanges, and not purchases, respondent's 25 On brief respondent uses the term "core amount" when refer-ring to the amount that Consolidated credited to each customer account receivable for each core that it acquired. In fact, the amount of such a credit was generally equal to the core amount, and we assume that respondent uses the term "core amount" for convenience. However, because of, inter alia, the condition of each customer core that a customer decided to deliver to Consol-idated, it was possible that Consolidated sometimes credited to a customer account receivable an amount that was less than the core amount. Unless we are quoting from the briefs of the parties, we shall refer to the amounts that Consolidated credited to each customer account receivable as the core credit amounts.Page: Previous 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 Next
Last modified: May 25, 2011