Rameau A. and Phyllis A. Johnson - Page 75

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            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,                                  





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