Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 75

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                    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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