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taxpayer’s] method of computing insurance expense there
was any procedure or intention to restore the excessive
deductions to income in future years so as to properly
reflect * * * [the taxpayer’s] total lifetime income.
* * * [66 T.C. at 596.]
Consequently, the Court concluded that the change in the
taxpayer’s practice of deducting insurance expenses did not
involve the question of the proper time for the taking of a
deduction, and therefore was not a change in a method of
accounting. Id. at 596-597. Accordingly, the Court concluded
that no adjustment to the taxpayer’s income could be made
pursuant to section 481(a) with respect to the balance of the
reserve account attributable to closed years. Id. at 597-598.
Subsequent cases have distinguished Schuster’s Express, Inc.
v. Commissioner, supra, concluding that the practices in question
involved issues of the timing of recognition of income, rather
than of the permanent avoidance of its reporting. Knight-Ridder
Newspapers, Inc. v. United States, supra; North Cent. Life Ins.
Co. v. Commissioner, 92 T.C. 254 (1989); Copy Data, Inc. v.
Commissioner, 91 T.C. 26 (1988); Primo Pants Co. v. Commissioner,
78 T.C. 705 (1982); Connors, Inc. v. Commissioner, 71 T.C. 913
(1979). Although petitioners argue that those cases are not
applicable to the situation presented in the instant case, the
circumstances noted by petitioners do not render the reasoning of
those cases inapposite.7 Knight-Ridder Newspapers, Inc. v.
7 For example, certain of those cases involve accrual method
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