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secure the consent of the Secretary before computing taxable
income under the new method. Sec. 446(e). Adoption of a method
of accounting for a new trade or business is not a change in the
method of accounting. Sec. 1.446-1(e)(1), Income Tax Regs. Use
of a method of accounting different from a taxpayer's overall
method of accounting is also not a change in the method of
accounting if it results from a change in underlying facts. Sec.
1.446-1(e)(2)(ii)(b), Income Tax Regs. For a different method of
accounting to be a change, "the item itself must be basically the
same as an item previously accounted for with the present method
of accounting differing from the prior treatment. Unless the
transactions are basically the same, the accounting treatment
would not be [a] 'change' of accounting but only a 'new'
accounting method for a different transaction." Federated Dept.
Stores, Inc. v. Commissioner, 51 T.C. 500, 513-514 (1968), affd.
426 F.2d 417 (6th Cir. 1970).
From 1979 through the years in issue, Woodbine's sales of
grave plots were recognized when cash was received, and most
expenses were recorded when paid. However, the costs of grave
plots were inventoried and expensed only as plots were sold.
When construction of the first mausoleum began in 1984,
mausoleum crypt sales were accounted for differently. Until
construction of the mausoleum was complete, customer payments to
purchase crypts were treated as deposits. When the mausoleum was
completed, prior payments were recognized as income, and the pro
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