- 81 -
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.
Page: Previous 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 Last modified: May 25, 2011