- 79 - result of the change, because the proper time for reporting this income under the accrual method would have passed. In cases (1) through (4) the accrual method would allow the Dealership to claim a deduction for expenses corresponding to amounts previously excluded from gross income. Since excluding an amount from income is essentially equivalent to recognizing income and offsetting it by a current deduction, the change in method of accounting would effectively result in the duplication of deductions. Cf. Western Cas. & Sur. Co. v. Commissioner, 571 F.2d 514, 519 (10th Cir. 1978), affg. 65 T.C. 897 (1976). The courts have repeatedly held that a change in method of accounting subject to section 481 results where a taxpayer is required to cease a practice of improperly reducing gross receipts by amounts allocable to a reserve for estimated losses or contingent liabilities. Knight-Ridder Newspapers, Inc. v. United States, supra; North Cent. Life Ins. Co. v. Commissioner, 92 T.C. 254 (1989); Copy Data, Inc. v. Commissioner, 91 T.C. 26 (1988); Klimate Master, Inc. v. Commissioner, T.C. Memo. 1981- 292. In substance, the cases at hand present the same issue and they require the same result. Petitioners correctly cite a number of our decisions for the proposition that correction of practices under which a taxpayer improperly excluded items from gross income does not necessarily constitute a change in method of accounting or may not otherwisePage: 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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