General Motors Corporation and Subsidiaries - Page 47




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          there is no method of accounting for the group as a whole.                   
          Furthermore, section 446 controls the determination of the method            
          of accounting.                                                               
               Section 446 supports the conclusion that the consolidated               
          return regulations are not a method of accounting.  Section                  
          446(c) lists four methods of accounting that are permissible:                
          (1) The cash method, (2) an accrual method, (3) any other method             
          permitted by chapter 1 of the Code, and (4) any permissible                  
          combination of the three aforementioned methods.  The                        
          consolidated return regulations are neither the cash method nor              
          an accrual method.  The consolidated return regulations are                  
          authorized under chapter 6 of the Code.  Section 446(c) and the              
          consolidated return regulations simply do not treat the                      
          regulations (or more specifically, the matching rule contained in            
          section 1.1502-13(b)(2), Income Tax Regs.) as a method of                    
          accounting.  See Vernon C. Neal, Inc. v. Commissioner, T.C. Memo.            
          1964-220.                                                                    
               Additionally, section 446(a) and (e) refer to the method of             
          accounting on the basis of which the taxpayer regularly computes             
          his income in keeping his books.  Corporations do not keep their             
          books based on the consolidated return regulations; the                      
          consolidated return regulations make adjustments to each                     
          corporation's income determined under each corporation's separate            
          method of accounting.  The Commissioner's supervisory authority              





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