John M. Cameron and Caroline D. Cameron, and John P. and Teena G. Broadaway - Page 10

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          no support in general principles of tax accounting.  On the                 
          contrary, the general rule for the timing of income accruals as             
          stated in the regulations is that "Where an amount of income is             
          properly accrued on the basis of a reasonable estimate and the              
          exact amount is subsequently determined, the difference, if any,            
          shall be taken into account for the taxable year in which such              
          determination is made."  Sec. 1.451-1(a), Income Tax Regs.  To              
          allow a taxpayer to reopen the taxable year of the original                 
          estimate would, moreover, be inconsistent with the annual                   
          accounting principle upon which the Federal income tax is                   
          predicated.  The courts have long maintained:                               
                    Income tax liability must be determined for annual                
               periods on the basis of facts as they existed in each                  
               period.  * * *  No other system would be practical in                  
               view of the statute of limitations, the obvious                        
               administrative difficulties involved, and the lack of                  
               finality in income tax liability, which would result.                  
               * * *                                                                  
          Estate of Block v. Commissioner, 39 B.T.A. 338, 341 (1939), affd.           
          sub nom. Union Trust Co. v. Commissioner, 111 F.2d 60 (7th Cir.             
          1940); accord Hillsboro Natl. Bank v. Commissioner, 460 U.S. 378,           
          377 & n.10, 378 n.11 (1983); Healy v. Commissioner, 345 U.S. 278,           
          284-285 (1953); Burnet v. Sanford & Brooks Co., 282 U.S. 359, 365           
          (1931).                                                                     
               It does not appear from the stipulated facts that an attempt           
          was made to correct the estimates reflected on Company's original           
          return for the taxable year ended October 31, 1988, by means of             
          an amended return.  The implication of petitioners' argument,               




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