James M. Rankin and Shirley Rankin - Page 15

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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             
                                                             (continued...)           




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