-75- * * * * * * * Taxation is transactional and not cuneiform. Our tax laws are not so supple that scraps of paper, regardless of their calligraphy, can transmute trade- ins into sales. Although [the taxpayer's] * * * transfers may have been paper sales, they were actual exchanges. A taxpayer may engineer his transactions to minimize taxes, but he cannot make a transaction appear to be what it is not. Documents record transactions, but they do not always become the sole criteria for transactional analysis. [Id. at 656, 659.] Redwing Carriers, Inc. v. Tomlinson, supra, is distin- guishable from the instant case for several reasons, including the following. Unlike the case before us, the Redwing Carriers, Inc., supra, case did not involve the inventory accounting issue under section 471 that is presented here. In Redwing Carriers, Inc. v. Tomlinson, supra, the respective prices at which the old trucks were transferred by the taxpayer and the new trucks were acquired by its subsidiary were set for tax purposes in excess of the aggregate fair market value of those trucks and were therefore not determined on the basis of market-related factors, such as supply and demand, and G.M.C. could have yielded a profit from the transactions in question only by viewing the alleged purchases of used trucks and the alleged sales of new trucks as one transaction. In contrast, we have found in the instant case that the remanufactured automobile part sales price (i.e., the price that Consolidated charged a customer who purchased a remanufactured automobile part) as well as the customer core purchase offer amount and the core credit amount (i.e., the pricePage: Previous 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 Next
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