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96-62, the training costs associated with the JITM conversion should be currently deductible.
220 (1985), in determining that costs for factory supervision, factory labor, factory training, indirect supervision and indirect labor incurred to establish a trained work force for each JITM cell were capitalizable under Sec.
Costs incurred to transform a manufacturing process to JITM were at issue in IRS Letter Ruling (TAM) 9544001.
To switch to JITM, a business may have to develop and implement new technologies in production, measurement, quality control, handling and assembly.
The facts in TAM 9544001 stated that JITM was a radical redesign of existing manufacturing processes resulting in a fundamental change in the business processes at the taxpayer's manufacturing facilities.
The JITM process generally combines several operations of production into a single work unit, or "cell." The goal is to eliminate nonutilized, work-in-process inventory by bringing manufactured units from a prior production stage to the next successive stage of production only when required.
The taxpayer adopted the JITM on a cell-by-cell basis to increase its productivity and competitiveness.
The Service found that the reconfiguration of the plants allowed the taxpayer to use its existing equipment in new and more efficient ways, and that the costs were part of an overall plan, capital in nature, to convert the taxpayer's facilities to the JITM. In addition to changing the physical characteristics of the plants, the plan required the acquisition of new equipment, and significantly improved the taxpayer's overall efficiency.
The Service viewed the conversion to the JITM as a "radical redesign of, and a fundamental change in" the business processes at the taxpayer's manufacturing facilities.
The taxpayer also incurred costs for materials and supplies used to implement the JITM. These items were not part of, nor consumed in producing, the finished manufactured product.
By enabling one worker to control many machines at once, the JITM greatly improves productivity and the ability to deliver a better and less costly product.
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