-88- record, we find that section 1.471-4(a), Income Tax Regs., and not section 1.471-4(b), Income Tax Regs., applies in determining the market for Consolidated's customer cores for purposes of section 471. We further find that the market under section 1.471-4(a), Income Tax Regs., is the replacement cost and that the replacement cost for each of the customer cores of Consolidated that were included in its inventories at the end of each of the years at issue is the core credit amount for a customer core of the same type that was prevailing at the end of each of those years. Based on our examination of the entire record in this case, we find that petitioner has not shown that respondent abused respondent's discretion in determining that Consolidated's FIFO- LCM method does not clearly reflect income because that method did not reflect the proper amounts for customer cores. To reflect the foregoing and the concession of petitioner for 1990, Decision will be entered for respondent.Page: Previous 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88
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