PNC Bancorp, Inc. Successor to First National Pennsylvania Corporation, et al. - Page 38

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          (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.                                                           


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