General Motors Corporation and Subsidiaries - Page 44




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          consolidated return regulations was a method of accounting.  See             
          id. at 622.  This Court subsequently followed Henry C. Beck                  
          Builders, Inc. in Vernon C. Neal, Inc. v. Commissioner, T.C.                 
          Memo. 1964-145, and in United Contractors, Inc. v. Commissioner,             
          T.C. Memo. 1964-68, affd. per curiam 344 F.2d 123 (4th Cir.                  
          1965).                                                                       
               In another Court-reviewed opinion issued 5 years after Henry            
          C. Beck Builders, Inc., the Court again rejected the IRS's                   
          argument that the intercompany transaction rules contained in the            
          consolidated return regulations were a method of accounting.  See            
          Henry C. Beck Co. v. Commissioner, 52 T.C. 1 (1969), affd. per               
          curiam 433 F.2d 309 (5th Cir. 1970) (Henry C. Beck Co.).  Citing             
          Henry C. Beck Builders, Inc., the Court stated that "Consolidated            
          returns are not a method of accounting but only a method of                  
          reporting."  Id. at 7-8.  Later in the opinion, we reemphasized              
          this point:  "As previously pointed out, it is well settled by               
          decisions of this Court that a consolidated return is merely a               
          method of reporting taxes, not a method of accounting."  Id. at              
          12.                                                                          
               Respondent correctly points out that Henry C. Beck Builders,            
          Inc. and Henry C. Beck Co. involved the consolidated return                  
          regulations in effect prior to 1966 (pre-1966 regulations), see              
          Henry C. Beck Co. v. Commissioner, supra at 11-12, and that the              
          case at bar involves the consolidated return regulations the                 





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