-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 price
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