39 We also pointed out in Electric & Neon, Inc. v. Commissioner, supra at 1333: while consistency is highly desirable when combined with some acceptable method of accounting, it is not a substitute for correctness; the respondent is justified in requiring a change in a taxpayer's method of accounting which, although consistently used over a period of years, is erroneous, and does not clearly reflect income. Accordingly, we find that the banks' current deduction of the costs associated with the origination of the loans did not clearly reflect their income and, therefore, was not a proper method of accounting.26 See also Commissioner v. Idaho Power Co., 418 U.S. at 14 ("capitalization prevents the distortion of income that would otherwise occur if depreciation properly allocable to asset acquisition were deducted from gross income currently realized."). It is apparent that the banks' current deduction of the costs at issue improperly accelerated the tax benefits derived from those costs and did not properly match the costs with the interest income produced by the loans. We find that capitalization of these expenses, subject to recovery by means of amortization over the life of the loans, does clearly reflect the banks' income and that respondent was within his broad authority to require this change. Legislative Necessity 26We note that petitioner did not offer any evidence to show how the current deduction of the costs at issue clearly reflects the banks' income.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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