- 14 - receipts and disbursements method; (2) an accrual method; (3) any other method permitted by this chapter; or (4) any combination of the foregoing methods permitted under regulations prescribed by the Secretary.” Sec. 446(c). The regulations permit “any combination of * * * [the cash, accrual, or other permissible] methods of accounting * * * if such combination clearly reflects income and is consistently used.” Sec. 1.446-1(c)(1)(iv), Income Tax Regs. A method of accounting includes an overall method and any specialized methods the taxpayer may use for individual items. Burck v. Commissioner, 63 T.C. 556, 561 (1975), affd. 533 F.2d 768 (2d Cir. 1976); sec. 1.446-1(a), Income Tax Regs. A taxpayer may adopt any permissible method of accounting on the first income tax return on which an item appears. Once a permissible method is chosen, the taxpayer must secure the consent of the Secretary before adopting a new method. Sec. 446(e). A change in the method of accounting includes a change in the overall plan of accounting or a change in the treatment of any material item used in the overall plan. Sec. 1.446- 1(e)(2)(ii)(a), Income Tax Regs. Petitioner contends that Mary Catherine has been using an inventory method of accounting, including LCM, since Mary Catherine’s inception. Respondent contends that real estate developers are not entitled to use inventory methods of accounting, such as LCM, for income tax purposes. RespondentPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011