38 (costs the taxpayer incurred in constructing signs with respect to which it was the lessor) as current deductions.25 Despite this error, the taxpayer requested that we approve its accounting method on the grounds that its method "clearly reflected income over a period of years, and that such practices had been consistently used over a long period of time." Id. at 1333. In holding that the taxpayer's improper characterization of capital expenditures failed to reflect income clearly, we stated: As a result of its use of an improper method, E & N's taxable income would be seriously understated in a year when many new signs were constructed for lease, and just as seriously overstated in a year when very few signs were constructed, with the result of making the corporation's financial fortunes appear to be sinking when in fact it was enjoying great success, and rising when in fact its business was seriously diminished. * * * "Income must be reflected with as much accuracy as recognized methods of accounting permit." Fort Howard Paper Co. [v. Commissioner], 49 T.C. 275, 284 (1967); see also Caldwell v. Commissioner, 202 F.2d 112, 115 [(2d Cir. 1953)], affirming on this issue a Memorandum Opinion of this Court. That E & N's accounting method with respect to the treatment of the cost of the leased signs fell short of this requirement is obvious. [Electric & Neon, Inc. v. Commissioner, supra at 1333.] 25The taxpayer in Electric & Neon, Inc. v. Commissioner, 56 T.C. 1324 (1971), affd. without published opinion 496 F.2d 876 (5th Cir. 1974), treated the entire costs of constructing the signs it subsequently leased, including materials, supplies, labor, freight, supervisory salary, workman's compensation insurance, payroll taxes, licenses, and miscellaneous job costs, as a current expense for Federal income tax purposes. Id. at 1326. Generally, the signs the taxpayer constructed had useful lives substantially beyond the taxable year of construction and the usual term for the original lease of these signs was 5 years. Id. at 1332-1333.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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