Rameau A. and Phyllis A. Johnson - Page 79

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            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 otherwise                          





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