USFreightways Corporation - Page 5




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          Thus, any attempt by respondent to require a change in this tax             
          accounting method constitutes, in petitioner’s view, an abuse of            
          discretion.                                                                 
               Conversely, respondent contends that, since a greater                  
          percentage of the costs at issue is allocable to 1994 than to               
          1993, the expenditures for licenses and insurance do result in              
          benefits to petitioner extending substantially beyond the taxable           
          year.  Therefore, respondent asserts that the costs must be                 
          capitalized and amortized.  In addition, respondent argues that             
          the distortion in taxable income caused by petitioner’s method of           
          tax accounting is sufficiently material to require a change in              
          methods in order to clearly reflect income.                                 
               We agree with respondent that petitioner, as an accrual                
          method taxpayer, is entitled to deduct expenses which are more              
          than incidental and allocable to future tax years only in the               
          taxable periods to which they relate.                                       
          General Rules                                                               
               As a threshold premise, section 446(a) states the general              
          rule: “Taxable income shall be computed under the method of                 
          accounting on the basis of which the taxpayer regularly computes            
          his income in keeping his books.”  The corollary to this rule,              
          with respect to the timing of deductions, is set forth in section           
          461(a) and reads: “The amount of any deduction or credit allowed            
          by this subtitle shall be taken for the taxable year which is the           






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