- 46 - indeterminate, but it would appear to us to follow the other factors that would attribute the full ownership of Woodbine to Alice Berger after March 14, 1989. Howard and Alice Berger owned the Woodbine property and business jointly during 1988 and until March 14, 1989. Thereafter Alice Berger was the sole owner of the Woodbine property and business until the sale of November 17, 1989. Issue 4(a). Method of Accounting for Mausoleum Sales and Costs Generally, a taxpayer computes taxable income using the same method of accounting that he or she regularly uses to compute income in keeping the books. Sec. 446(a). A taxpayer may use "(1) the cash receipts and disbursements method; (2) an accrual method; (3) any other method permitted by this chapter; or any combination of the foregoing methods permitted under regulations prescribed by the Secretary." Sec. 446(c). The regulations permit "any combination of * * * [the cash, accrual, or other permissible] methods of accounting * * * if such combination clearly reflects income and is consistently used." Sec. 1.446- 1(c)(1)(iv), Income Tax Regs. A method of accounting includes both the taxpayer's overall method of accounting and the method of accounting for any item. Burck v. Commissioner, 63 T.C. 556, 561 (1975), affd. 533 F.2d 768 (2d Cir. 1976); sec. 1.446-1(a), Income Tax Regs. If a taxpayer changes the method of accounting regularly used to compute income in keeping the books, the taxpayer mustPage: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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