General Motors Corporation and Subsidiaries - Page 46




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          that the consolidated return regulations were not a method of                
          accounting.                                                                  
               We do not believe that the 1966 regulations undercut the                
          holdings in Henry C. Beck Builders, Inc. and Henry C. Beck                   
          Co. that the consolidated return regulations are a method of                 
          reporting and not a method of accounting.  To the contrary, the              
          1966 regulations fortify the reasoning contained in Henry C. Beck            
          Builders, Inc. and Henry C. Beck Co.                                         
               Respondent adopted sections 1.1502-12(d) and 1.1502-17,                 
          Income Tax Regs., as part of the 1966 regulations.  These                    
          sections provide the rules for determining methods of accounting             
          and changes in method of accounting under the consolidated return            
          regulations.                                                                 
               Section 1.1502-12(d), Income Tax Regs., states that the                 
          method of accounting under which the computation of separate                 
          taxable income of each member of the consolidated group is made              
          and the adjustments to be made because of any change in method of            
          accounting shall be determined under section 1.1502-17, Income               
          Tax Regs.  Section 1.1502-17, Income Tax Regs., entitled "Methods            
          of accounting", states that "The method of accounting to be used             
          by each member of the group shall be determined in accordance                
          with the provisions of section 446 as if such member filed a                 
          separate return."  Thus, each member (and not the group)                     
          determines its method of accounting on a separate company basis--            





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