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for calculating depreciation. On the other hand, to accept
respondent’s position and summarily decline to equate the changes
would significantly curtail the exception’s usefulness under the
current section 168 regime.
We conclude that the former option is most consistent with
the regulatory scheme. The similarities between a change in
MACRS classification and a change in useful life are greater than
the differences. Section 1.446-1(e)(2)(ii)(b), Income Tax Regs.,
was clearly intended to permit taxpayers to alter their
depreciation schedules. The type of adjustment explicitly
permitted--a change in useful life--would have resulted both in
depreciation deductions over a longer or shorter period than
originally contemplated and in an increased or decreased amount
being deducted in any given period. A change in MACRS
classification will have precisely these same two effects.
Although a portion of the change in amount may be attributable to
calculation method, as opposed to period length alone, such
carries insufficient weight when balanced against severely
limiting the intended relief.
We therefore hold that the filing of returns for the years
ended in 1996 and 1997 which depreciated the gas stations as 15-
year property did not result in an unauthorized change in
petitioner’s method of accounting. Petitioner’s change in MACRS
classification is excluded from the definition of a change in
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