Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person - Page 88

                                        -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  

Last modified: May 25, 2011