Rameau A. and Phyllis A. Johnson - Page 81

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            accounting, the Commissioner had improperly computed the section                          
            481 adjustment by including certain items that did not constitute                         
            taxable income, items that may already have been included in the                          
            taxpayer's income, and items for which an offsetting deduction                            
            would have been allowable under the proper method for the year of                         
            the change.                                                                               
                  None of the authorities on which petitioners rely conflicts                         
            with the section 481 analysis set forth above.  We conclude that                          
            an adjustment under section 481 is proper.14                                              
                  To reflect the foregoing,                                                           

            Decisions will be entered                                                                 
            under Rule 155.                                                                           


















                  14 The sec. 481 adjustment must be recomputed under Rule 155                        
            in accordance with the treatment for Fees prescribed herein.                              




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