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In support of respondent's position that Consolidated
acquired customer cores in purchase transactions, respondent
asserts:
The parties have stipulated that when Consolidated
sells a remanufactured automobile part to a customer,
it receives a total sales amount. * * * The total sales
amount, consisting of the exchange amount plus core
amount, is taken into income as a cash/credit
transaction. * * * A customer core may or may not
subsequently be acquired by Consolidated at the core
amount. If it is, this is a separate cash/credit
transaction whereby Consolidated is out-of-pocket the
core amount. * * * The [customer core sales] invoices
* * * use the term "price each", not "refund" or
"deposit" when referring to the value given up by
Consolidated for cores provided to Consolidated by its
customers. These stipulated facts are not indicative
of an "exchange transaction" as advocated by
petitioner. These facts also do not support the
proposition that the customer cores are obtained by
Consolidated at little or no out-of-pocket cost.
* * * * * * *
Petitioner acknowledges that Consolidated's
customers do not generally provide a core to
Consolidated at the time a remanufactured part is sold.
In fact, an entire year may go by before a customer
provides a core. Nevertheless, petitioner presents a
scenario in support of the exchange argument in which
the core is provided simultaneously. Petitioner has
not established in the record that such a scenario is
treated any differently than a normal core acquisition.
It is instructive to consider the scenario wherein
Consolidated knows, at the time that a remanufactured
part is sold, that the customer cannot provide a core.
The stipulated facts indicate the customer would still
pay the core amount although there is no possible core
return to be "secured".
Petitioner's argument that it acquires cores in an
integrated transaction does not comport with the facts.
Consolidated's customers are not required to provide a
core. The remanufactured part is not sold to the
customer contingent upon a core being provided. There
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