Buyers Home Warranty Company - Page 8

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          arguments.  First, petitioner asserts that it was not "required"            
          to change its accounting method pursuant to section 1.481-                  
          1(c)(5), Income Tax Regs.  Second, petitioner alleges that Rev.             
          Proc. 92-20, 1992-1 C.B. 685, violates equal protection.                    
               Section 1.481-1(c)(5), Income Tax Regs., provides that "A              
          change in the taxpayer's method of accounting required as a                 
          result of an examination of the taxpayer's income tax return will           
          not be considered as initiated by the taxpayer."  (Emphasis                 
          supplied.)  Both the regulations and Rev. Proc. 92-20, supra,               
          differentiate between accounting method changes initiated by the            
          taxpayer and those initiated by the Commissioner.  The year of              
          change is more favorable if the change is initiated by the                  
          taxpayer.                                                                   
               Petitioner asserts the following:  During the audit, the IRS           
          suggested petitioner be treated as a warranty company.  In                  
          response, petitioner proposed, as a compromise, that it be                  
          treated as an insurance company.  According to petitioner, that             
          compromise was accepted by respondent via the technical advice              
          memorandum.  Because it was a "compromise", petitioner argues               
          that "there was no requirement that petitioner change accounting            
          methods."  Petitioner's Opening Brief, p. 9.                                
               Despite the spin petitioner attempts to place on events,               
          nothing in the record indicates that petitioner initiated any of            
          the events relating to its change of accounting method.  The                





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