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that Consolidated paid to acquire a customer core) were
determined on the basis of market-related factors, such as supply
and demand. We conclude that Redwing Carriers, Inc. v.
Tomlinson, 399 F.2d 652 (5th Cir. 1968), does not control our
resolution of the issue presented here.
Nor does Burrell v. Commissioner, 400 F.2d 682 (10th Cir.
1968), govern our resolution of the inventory accounting issue
under section 471 that is involved in the instant case. In
Burrell v. Commissioner, supra, the Court of Appeals for the
Tenth Circuit, to which an appeal in this case would generally
lie, recited the facts on which it relied as follows:
In 1962, William P. Burrell,* * * as a sole
proprietor, was engaged in reboring automobile engine
blocks, called "cores," using them to rebuild
automobile engines which he sold to both retail and
wholesale customers. In order to maintain an inventory
of cores to be rebored, Burrell desired that each
customer to whom he sold a rebuilt engine with a
rebored core therein, deliver to him the old core in
the automobile engine which the rebuilt engine
replaced, or a like old core from an automobile engine
of the same make.
The amount of the bill which Burrell rendered to
customers who purchased from him rebuilt engines with
rebored cores was for a single amount, which, in fact,
was made up of two items. Such items were reflected
separately on an invoice furnished to the customer.
Item One on such invoice was for the rebuilt engine.
Item Two was for the core from the old engine, or a
substitute therefor, to be delivered to Burrell by the
customer.
* * * * * * *
When a new core was returned, Item Two was
cancelled, although the actual value of the old core
did not equal the amount of the Item Two charge. Such
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