- 23 - v. Commissioner, 62 T.C. 469, 479-481 (1974), affd. 536 F.2d 874 (9th Cir. 1976). Accordingly, we consider cases dealing with material distortions of income arising in connection with the claim of deductions. In Van Raden v. Commissioner, 71 T.C. at 1105-1106, we set forth the following approach to considering the question whether a distortion of income was material: Because the method of accounting and the nature of the trade or business are so interdependent, we conclude that the distortion of income must not be examined in a vacuum but in light of the business practice or business activities which give rise to the transaction which the Commissioner has determined must be accorded a different accounting treatment. For example, material distortions of income may occur if the sales force of a business is more successful in December than in January, yet such a distortion would not require adjustment to clearly reflect income because the distortion resulted from the business activity itself. * * * A material distortion of income generally does not occur where a deferral of income arises in the regular course of business and not from a manipulation of the cash method. Gold- Pak Meat Co. v. Commissioner, 522 F.2d 1055, 1057 (9th Cir. 1975), remanding T.C. Memo. 1971-83. Courts have also considered whether a business purpose exists for a transaction in deciding whether a taxpayer's method of accounting for the transaction materially distorts income. Frysinger v. Commissioner, supra at 528; Packard v. Commissioner, supra at 428-430; Van Raden v. Commissioner, 71 T.C. at 1105-1106. A business purpose exists where the taxpayer establishes a reasonable expectation of receiving some business benefit from the aspect of thePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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