- 12 - (2) there shall be taken into account those adjustments which are determined to be necessary solely by reason of the change in order to prevent amounts from being duplicated or omitted, except there shall not be taken into account any adjustment in respect of any taxable year to which this section does not apply unless the adjustment is attributable to a change in the method of accounting initiated by the taxpayer. By its terms, section 481 applies only when there is a change in method of accounting. Section 1.446-1(e)(2)(ii)(a), Income Tax Regs., describes a change in method of accounting as follows: “A change in the method of accounting includes * * * a change in the treatment of any material item * * * A material item is any item which involves the proper time for the inclusion of the item in income or the taking of a deduction.” In other words, a change in method of accounting does not involve whether or not an item of income is included, but when. See Knight-Ridder Newspapers, Inc. v. United States, 743 F.2d 781, 798 (11th Cir. 1984). However, the regulations provide several specific limitations: A change in method of accounting does not include correction of mathematical or posting errors, or errors in the computation of tax liability * * * . Also, a change in method of accounting does not include adjustment of any item of income or deduction which does not involve the proper time for the inclusion of the item of income or the taking of a deduction. * * * A change in the method of accounting also does not include a change in treatment resulting from a change in underlying facts. * * * [Sec. 1.446-1(e)(2)(ii)(b), Income Tax Regs.]Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011