-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 "extraordinaryPage: Previous 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 Next
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