- 10 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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