Rameau A. and Phyllis A. Johnson - Page 78

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            Dealership is treated as owner of the PLRF, to include investment                         
            income as it accrues.  For cases (1) through (4), a deduction is                          
            allowable for the year in which the expense is incurred or, if                            
            capitalized, the year in which it is taken into account through                           
            amortization.                                                                             
                  Thus, the Dealership's practice resulted in permanent                               
            exclusion only where a deduction would have been allowable for a                          
            later period.  Compared with the proper application of the                                
            accrual method, the Dealership's practice had the effect of                               
            either deferring income (cases (5) and (6)) or accelerating a                             
            deduction (cases (1) through (4)).  Correction of this practice                           
            cannot affect the Dealership's lifetime taxable income under any                          
            circumstances:  it can only affect the time when an increase or                           
            offsetting reduction to lifetime income is taken into account.                            
            Cf. Knight-Ridder Newspapers v. United States, 743 F.2d 781, 798-                         
            799 (10th Cir. 1984).  Accordingly, the correction represents a                           
            change in method of accounting for purpose of section 481.                                
                  The second requirement for application of section 481 is                            
            that, in the absence of an adjustment for prior years, amounts                            
            would be duplicated or omitted in the computation of taxable                              
            income solely by reason of the change in method of accounting.                            
            This requirement is also satisfied.  Income attributable to                               
            contracts in prior years which the Dealership would have reported                         
            in some later years in cases (5) and (6) would be omitted as a                            





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