Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 66

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          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.                                                                    




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