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increase in value should have no impact on depreciation, provided
that the original determination was reasonable. Id. at 276-278.
Fribourg did not contemplate the effect of an adjustment to
the original depreciable basis on the annual straight line
depreciation allowance. Additionally, Fribourg did not consider
whether the adjusted depreciable basis should be further adjusted
by previously allowed depreciation in order to arrive at the
proper remaining basis for depreciation. Rather, Fribourg
addressed the impact of fluctuations in the market value
subsequent to the original determination of salvage value.
We conclude that respondent's method of calculating the
allowable amortization deduction would neither contravene the
annual accounting concept nor disregard the statute of
limitations. Federal income taxes are generally assessed on the
basis of annual returns showing the net result of all the
taxpayer's transactions during a fixed accounting period. Burnet
v. Sanford & Brooks Co., 282 U.S. at 363. Although each year
stands separately, and an error made in computation of the tax
for one year cannot be corrected by making an erroneous
computation under the law of a later year, Greene Motor Co. v.
Commissioner, 5 T.C. 314, 316 (1945); MacMillan Co. v.
Commissioner, 4 B.T.A. 251, 253 (1926), the annual accounting
concept does not require us to close our eyes to what happened in
prior years, United States v. Skelly Oil Co., 394 U.S. 678, 684
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