- 22 - record that suggests that the office managers reported on their tax returns a portion of the income and expense associated with their respective offices. Indeed, petitioners assert that petitioners' income tax returns and the surety's ledgers with respect to the BUF accounts in issue contain all the information needed for purposes of the alternative method provided by section 481(b)(2), further discussed below, for computing the amount of the additional tax to be paid as a result of the adjustment required due to the change in the method of accounting for the BUF accounts. Petitioners' assertions and the record as a whole indicate that the full amount of the payments into the BUF accounts were taken as offsets against the gross receipts of petitioner's bail bond business reported on petitioners’ tax returns, and petitioners do not contend otherwise. We conclude that petitioners have not established that any of the BUF accounts in issue were jointly owned. Accordingly, no modification of the amount of the section 481(a) adjustment is required for this reason. Petitioners also contend that, in the event we decide that section 481(a) applies in the instant case, the amount of tax resulting from the adjustment should be limited to the amount computed pursuant to section 481(b)(2).13 Respondent contends 13 Petitioners do not rely on the limitation provided by sec. 481(b)(1), and we do not consider it.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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