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inventory as may be available, such as specific
purchases or sales by the taxpayer or others in
reasonable volume and made in good faith, or
compensation paid for cancellation of contracts for
purchase commitments. * * *
The Supreme Court of the United States has held that the
term "current bid price" used in section 1.471-4(a), Income Tax
Regs., is synonymous with the "replacement cost, that is, the
price the taxpayer would have to pay on the open market to
purchase or reproduce the inventory items." Thor Power Tool Co.
v. Commissioner, supra at 534. The current bid price is to be
determined based on prevailing prices in the market in which the
taxpayer actually participates. D. Loveman & Son Export Corp. v.
Commissioner, 34 T.C. 776, 799 (1960), affd. 296 F.2d 732 (6th
Cir. 1961); Bamert v. Commissioner, supra at 1100.
Based on our examination of the entire record before us, we
find that Consolidated acquired its customer cores under
ordinary, and not extraordinary, circumstances. In acquiring
customer cores, Consolidated participated in the marketplace in
which it purchased those cores from its customers, and not in the
marketplace in which it purchased core supplier cores from core
suppliers. We further find that petitioner has failed to
persuade us either that the marketplace in which Consolidated
acquired customer cores from its customers is not an open market
in which Consolidated participated within the meaning of section
1.471-4(b), Income Tax Regs., or that Consolidated did not
acquire its customer cores in an open market. On the instant
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