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involve the proper time for the inclusion of the item of income
or the taking of a deduction”).
We consider first the Charleston County Court and U.S.
District Court accounts. Here, the instant case is
indistinguishable from Rankin. As in Rankin, respondent’s change
of petitioner’s treatment of the amounts deposited into the
accounts was a change in method of accounting, because it
affected only the timing of inclusion, not the ultimate fact of
inclusion. Under petitioner’s method, he would have been
required to include in income the funds in the accounts in the
year they ultimately became available to him.9 Any amounts
actually paid to satisfy forfeited bonds would not be included.10
Under respondent’s method, petitioner would be required to
include in income the funds in the accounts in the year of
deposit, but he would be entitled to deductions for amounts
actually paid to satisfy forfeited bonds, so the total amount
required to be included in income would be the same. Thus,
respondent’s method alters only the timing of inclusion, not the
9 The evidence establishes that petitioner was entitled to
receive all of the amounts in the Charleston County Court account
when his bond obligations were completely satisfied. The same
appears to be true of the U.S. District Court account; at the
least, there is no evidence, or suggestion, to the contrary.
10 As we have found, no funds from the Charleston County
Court account were used to satisfy a forfeiture before or during
the years in issue.
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