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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 must
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