- 49 - permission. For examples of situations where certain modifications in the accrual of items under the all-events test were held to constitute not “changes” in methods of accounting for such items but mere “corrections” in the application to such items of the all-events test of the accrual method of accounting (for which corrections respondent’s permission was not required) see Northern States Power Co. v. United States, 151 F.3d 876, 883-885 (8th Cir. 1998); Gimbel Bros., Inc. v. United States, 210 Ct. Cl. 17, 535 F.2d 14, 21-23 (1976); Standard Oil Co. v. Commissioner, 77 T.C. 349, 381-383 (1981). In Ohio River Collieries Co. v. Commissioner, 77 T.C. 1369 (1981), we recognized that under the all-events test accrual of estimated strip-mining reclamation costs as ordinary and necessary business expenses may be appropriate in the year the land is disturbed, rather than in the year the reclamation work is performed. Arguably, in light of that case, Exxon’s attempted modification to the accrual of estimated DRR costs from the year DRR work is performed to the year in which wells are drilled would qualify as a mere correction in Exxon’s method of accounting for such well-site DRR costs for which respondent’s permission would not be required. In light, however, of our resolution of the next issue we need not, and we do not, decide this issue. Distortion of IncomePage: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
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