Golden Gate Litho - Page 29

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          accounting different from the method under which the taxpayer's             
          income for the preceding taxable year was computed, there shall             
          be taken into account those adjustments which are determined to             
          be necessary solely by reason of the change in order to prevent             
          an amount from being duplicated or omitted.  Since we have held             
          that petitioner is not required to change from the cash method              
          for the taxable year at issue, petitioner's taxable income is               
          computed under the same method of accounting as in the previous             
          taxable year.  Therefore, petitioner is not subject to any                  
          adjustments under section 481.                                              
                                        III                                           
          Whether Petitioner Is Liable for the Accuracy-Related Penalty               
          Under Section 6662(a)                                                       
               In its brief, petitioner addressed the accuracy-related                
          penalty only with respect to the change in accounting method.               
          Petitioner concedes that it is not entitled to deduct the loss              
          on the sale of an automobile.  The deficiency to be computed                
          under Rule 155 is attributable solely to the disallowance of                
          that loss.  Therefore, we hold petitioner is liable for the                 
          accuracy-related penalty under section 6662(a).                             
               To reflect the foregoing and because of the concessions by             
          the parties,                                                                

                                             Decision will be entered                 
                                        under Rule 155.                               





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Last modified: May 25, 2011