-80- Based on our examination of the entire record in this case, we reject petitioner's position that Consolidated acquired customer cores in exchange transactions in which Consolidated's customers purchased remanufactured automobile parts from it in exchange for the payment by them of the exchange amounts and delivery by them of customer cores to Consolidated. On that record, we find that the substance of the transactions by which Consolidated acquired customer cores were purchases in which Consolidated purchased customer cores for the prices that were shown in the customer core sales invoices under the column headed "Cores--Price Each". We shall now address what the cost and the market are for purposes of section 471 for the customer cores that Consolidated acquired.27 The Cost for Consolidated's Customer Cores For purposes of inventory accounting under section 471, the cost of merchandise purchased is determined under section 1.471- 3, Income Tax Regs. That section provides in pertinent part: Cost means: * * * * * * * 27 Assuming arguendo that we were to have found that Consolidated’s acquisitions of customer cores were exchanges, and not purchases, our findings below as to the cost and the market for Consolidated's customer cores for purposes of sec. 471 would not change.Page: Previous 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 Next
Last modified: May 25, 2011