- 75 - Sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs. In determining whether a change in a reporting practice involves the proper time for the inclusion or deduction of an item, the relevant question generally is whether the change affects the aggregate amount of taxable income over the taxpayer's lifetime. If the change affects the amount of taxable income for 2 or more taxable years without altering the taxpayer's lifetime taxable income, then it is strictly a matter of timing and constitutes a change in method of accounting. Copy Data, Inc. v. Commissioner, 91 T.C. 26, 30- 31 (1988); Schuster's Express, Inc. v. Commissioner, 66 T.C. 588, 597 (1976), affd. without published opinion 562 F.2d 39 (2d Cir. 1977). Petitioners argue that respondent's adjustments to the method used by the Dealerships to report income and expense under the VSC program do not trigger application of section 481. They correctly point out that to the extent unreported amounts were ultimately refunded to the purchaser or paid to Travelers, the Administrator, the Administrator’s sales agent, BPI, or other authorized repair facilities, the Dealerships’ reporting practice resulted not in deferral of income but rather in permanent exclusion. "Here * * * the issue is whether income should be reported by the Dealerships, not when it should be reported. The amounts which Respondent proposes to include in a Code sec. 481 adjustment were not reported at all." Consequently,Page: Previous 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 Next
Last modified: May 25, 2011