-84-
We find the foregoing cases on which petitioner relies to be
distinguishable from the instant case and petitioner's reliance
on them to be misplaced. None of those cases involved the issue
of the proper amounts at which a taxpayer must reflect property
in such taxpayer's inventories. Moreover, unlike the cases (viz,
Majestic Sec. Corp. v. Commissioner, 120 F.2d 12 (8th Cir. 1941),
affg. 42 B.T.A. 698 (1940); Lemmen v. Commissioner, 77 T.C. 1326
(1981); and New Hampshire Fire Ins. Co. v. Commissioner, 2 T.C.
708 (1943), affd. 146 F.2d 697 (1st Cir. 1945)) on which
petitioner relies in which the respective purchasers involved
there paid more than fair market value for the assets that they
purchased, we have found on the record before us that the amounts
for which Consolidated acquired customer cores were based on
market-related factors, including supply and demand, and were set
at amounts that the marketplace in which Consolidated purchased
those cores demanded.
On the record before us, we find that for purposes of
section 471 the cost for each of the customer cores that
Consolidated acquired is the price (viz, the core credit amount
for each such core) which it paid for each such core and which is
shown under the column headed "Cores--Price Each" on the customer
cores sales invoice that was prepared at or about the time a
customer delivered such a core to Consolidated.
The Market for Consolidated's Customer Cores
Petitioner contends that, as a result of "extraordinary
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