- 20 - The regulations define “material item” as “any item which involves the proper time for the inclusion of the item in income or the taking of a deduction.” Sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs.12 The regulations also define certain situations in which a change does not rise to the level of a change in method of accounting. Specifically, section 1.446-1(e)(2)(ii)(b), Income Tax Regs., provides: A change in method of accounting does not include correction of mathematical or posting errors, or errors in the computation of tax liability * * *. Also, a change in method of accounting does not include adjustment of any item of income or deduction which does not involve the proper time for the inclusion of the item of income or the taking of a deduction. * * * A change in the method of accounting also does not include a change in treatment resulting from a change in underlying facts. * * * 1. Unauthorized Change After Richardson I Respondent determined that Investments originally elected to define its inventory units for its new car pool by model code but 12 Sec. 472 and the regulations thereunder provide more specific guidance on when a change in method occurs in the LIFO method of accounting. Sec. 472(e) provides that a taxpayer may not change from the LIFO method to another method of inventory accounting without the consent of the Commissioner. With respect to the dollar-value method of LIFO, the regulations provide that a taxpayer may not change its pricing method, e.g., link-chain method, without the consent of the Commissioner. Sec. 1.472- 8(e)(1), Income Tax Regs. In addition, the regulations provide that any change in pooling used in computing LIFO inventories requires the consent of the Commissioner. Sec. 1.472-8(g)(1), Income Tax Regs. Here, respondent does not argue that Investments changed its overall method of accounting for inventory, i.e., the dollar-value LIFO method, nor does she argue that Investments changed its overall pricing method or the number of pools it utilized.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011