- 48 -
over accounting methods simply is not implicated here. See sec.
1.1502-17, Income Tax Regs.
It was not until 1995 that section 1.1502-13, Income Tax
Regs., was amended to state that the timing rules contained in
the consolidated return regulations are a method of accounting.28
See sec. 1.1502-13(a)(3), Income Tax Regs., as amended ("The
timing rules of this section are a method of accounting for
intercompany transactions, to be applied by each member in
addition to the member's other methods of accounting."); T.D.
8597, 1995-2 C.B. 147, 162.
Petitioner also argues that on a separate company basis GM
and GMAC did not change their respective methods of accounting
for the rate support payments or discount income. We agree. GM
always treated rate support payments as current deductions, and
GMAC always recognized discount income over the life of the
RISC/fleet loan. It was only when the GM group filed a
consolidated return that, on this return, the GM group deferred
the rate support deductions that, according to GM's accounting
method, GM was currently deducting.
28 The 1995 amendments are effective as of July 18, 1995,
and apply to transactions occurring in years beginning on or
after July 12, 1995. See T.D. 8597, 1995-2 C.B. 147, 185; sec.
1.1502-13(l)(1), Income Tax Regs., as amended. The 1995
amendments are not before the Court; therefore, we make no
conclusions as to whether these amendments are valid.
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