Rameau A. and Phyllis A. Johnson - Page 74

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            4.  Section 481 Adjustment                                                                
                  Respondent made an additional adjustment to the income of                           
            petitioner DFM Investment Co. for its taxable year ended                                  
            March 31, 1990, pursuant to section 481.  The adjustment purports                         
            to reflect the aggregate of the unreported income realized from                           
            the sale of VSC's in prior taxable years plus accumulated                                 
            investment income, reduced by allowable deductions for refunds,                           
            payments to other repair facilities, Commissions, and an                                  
            amortization allowance for Premiums.  The controversy concerns                            
            whether section 481 authorizes an adjustment under the                                    
            circumstances of this case.                                                               
                  Section 481(a) provides that where taxable income for any                           
            year is computed under a method of accounting that is different                           
            from the method used for the preceding year, then the computation                         
            of taxable income for the year of the change shall take into                              
            account those adjustments that are determined to be necessary                             
            solely by reason of the change in order to prevent amounts from                           
            being duplicated or omitted.  A change in method of accounting to                         
            which section 481 applies includes a change in the overall plan                           
            of accounting for gross income or deductions or a change in the                           
            treatment of any material item used in the overall plan.  Secs.                           
            1.481-1(a)(1), 1.446-1(e)(2)(ii)(a), Income Tax Regs.  A material                         
            item is "any item which involves the proper time for the                                  
            inclusion of the item in income or the taking of a deduction."                            





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