Alice Berger, et al. - Page 46

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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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