Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 84

                                        -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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