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* * * omitted”. Further, it is well established that section 481
supersedes the statute of limitations. See Graff Chevrolet Co.
v. Campbell, 343 F.2d 568 (5th Cir. 1965); Superior Coach, Inc.
v. Commissioner, 80 T.C. 895, 912 (1983). If petitioner merely
changed, starting in 1992, to an accounting method under which
amounts are included in income when received from clients, this
method would not result in the inclusion in income of amounts
previously excluded because deposited into the court and in-house
accounts. Without section 481, such amounts would generally
escape taxation. Section 481 allows respondent to prevent such
omissions by requiring petitioner to include in income in 1992
the amounts previously accumulated in the three accounts.
Petitioner argues that section 481 does not apply because
there has been no change in method of accounting. It is true
that a change in method of accounting is necessary to trigger
section 481, but petitioner’s attempts to show that there was no
change in method are unavailing. Petitioner first argues that
there was no change in method of accounting, relying on section
1.446-1(e)(2)(ii)(b), Income Tax Regs., which provides that “A
change in the method of accounting * * * does not include a
change in treatment resulting from a change in underlying facts.”
However, although petitioner argues in general that there was a
change in underlying facts, he points to no such change, and we
have found none.
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