- 74 - 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."Page: Previous 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 Next
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