Color Arts, Inc., John P. Csepella, A Person Other Than The Tax Matters Person - Page 11




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          opening and ending inventory for fiscal year 1982 on the basis of           
          a complete physical inventory [was] a change in the treatment of            
          a material item and, therefore, constitutes a change in                     
          accounting method.”  Id. at 511; accord Knight-Ridder Newspapers,           
          Inc. v. United States, supra; Firetag v. Commissioner, T.C. Memo.           
          1999-355 (the Commissioner’s determination that the taxpayer had            
          previously used an improper method of accounting which involved a           
          systematic and consistent treatment of a significant item was not           
          a computational or posting error but rather a change in his                 
          method of accounting), affd. 232 F.3d 887 (4th Cir. 2000).                  
               The Court of Appeals for the Seventh Circuit, to which this            
          case is appealable, has decided a substantially similar case.  In           
          Peoples Bank & Trust Co. v. Commissioner, 415 F.2d 1341 (7th Cir.           
          1969), affg. 50 T.C. 750 (1968), the taxpayer was a calendar                
          year, overall accrual method bank which paid interest on its                
          savings accounts.  Because of the interplay between when the                
          taxpayer paid interest and its tax year, for 2 months of the year           
          the taxpayer calculated its interest expense on the basis of a              
          “fairly accurate” experience factor, although the interest was              
          not payable until the following tax year.  Like here, the                   
          interest expense failed the “all events test” the Commissioner              
          corrected the taxpayer’s method, and imposed a section 481(a)               
          adjustment.  This Court agreed with the Commissioner and                    
          sustained his determination finding that the taxpayer’s method of           






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