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CONSOLIDATED MFG., INC. v. COMMISSIONER INT. REV.

No. 98-9027.

249 F.3d 1231 (2001)

CONSOLIDATED MANUFACTURING, INC.; M.P. Long Living Trust; Merl Philip Long, Trustee, Tax Matters Person, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

May 8, 2001.

Attorney(s) appearing for the Case

Eric S. Namee (James Scott MacBeth with him on the briefs), of Hinkle Elkouri Law Firm, Wichita, Kansas, for Petitioners-Appellants.

Charles Bricken (Jonathan S. Cohen with him on the brief), Attorneys, Tax Division, Department of Justice, Washington, DC, for Respondent-Appellee.

Before TACHA, Chief Judge, SEYMOUR and EBEL, Circuit Judges.

EBEL, Circuit Judge.

This case involves financial accounting issues in the context of income taxation. Consolidated Manufacturing purchases used car parts, called "cores," rebuilds the cores with new components, and then sells them. Consolidated uses a pricing system that encourages its customers for the rebuilt products to send a replacement core back to it. In this way, Consolidated ensures a continuous supply of its primary raw material — the cores. The...

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