Barnett Banks of Florida, Inc. and Subsidiaries - Page 19

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          taxpayer's books and records and all reports to shareholders,               
          partners, other proprietors or beneficiaries and for credit                 
          purposes.  Rev. Proc. 71-21, sec. 3.11.  Petitioner uses the same           
          method for financial, regulatory, and tax accounting purposes and           
          thus satisfies this requirement.  Taxpayers who avail themselves            
          of this procedure must maintain adequate books and records so               
          that the amount deferred on the income tax return for any year              
          can be verified.  Rev. Proc. 71-21, sec. 4.  The parties have               
          stipulated that petitioner's books and records satisfy this                 
          requirement.                                                                
               Petitioner relies on Rev. Proc. 71-21 for its method of                
          accounting for these annual credit card fees.  Section 3.14 of              
          Rev. Proc. 71-21 provides that the deferral of income in                    
          accordance with this procedure will be treated as an acceptable             
          method of accounting under section 446 as long as the method is             
          consistently used by the taxpayer.  Petitioner consistently used            
          the same method of accounting for these fees from the time it               
          instituted the fees in October of 1980 through the taxable year             
          1985.9                                                                      
               Respondent cites section 3.06 of Rev. Proc. 71-21 and argues           
          that since petitioner has not correlated the fees to specific               
          services, petitioner is unable to avail itself of Rev. Proc. 71-            


          9  Respondent seems to argue on brief that petitioner                       
          improperly changed its accounting method without obtaining                  
          respondent's consent.  That is not the case.                                




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