- 17 - outstanding at the end of 1990 be recognized as income in 1990. [Petitioner] objected to this proposed change in accounting because it required the inclusion in income in 1990 of interest on installment note payments that are not due at the end of 1990 and won't be due for months or even years in the future. According to petitioner, respondent has, in effect, placed petitioner on an erroneous method of accounting to the extent that respondent computes petitioner's income by reference to unearned interest and has, thus, exceeded her authority to change petitioner's method of accounting under section 446(b). We disagree. Neither the purpose nor the necessary effect of respondent's adjustment is to include in petitioner's gross income for 1990 interest that will accrue after 1990. As described above, petitioner treated interest as having been earned only when a loan was fully paid off or petitioner repossessed the automobile securing the loan and the loan was closed on petitioner's books. The change of accounting method that was made by respondent is to require interest to be ratably included in petitioner's income over the life of the loan. Based upon petitioner's records of loans outstanding at the end of 1990, respondent's agent found that interest in the amount of $3,084,179 had been earned through the end of 1990. Petitioner does not attack that computation.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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