- 13 - I. Method of Accounting Section 446(a) provides that “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 term “method of accounting” includes both the “over-all method of accounting” and “the accounting treatment of any item.” Sec. 1.446-1(a)(1), Income Tax Regs. A method of accounting includes “the consistent treatment of a recurring, material item, whether that treatment be correct or incorrect.” H.F. Campbell Co. v. Commissioner, 53 T.C. 439, 447 (1969), affd. 443 F.2d 965 (6th Cir. 1971). A taxpayer changes its method of accounting when it changes either the “overall plan of accounting for gross income or deductions” or “the treatment of any material item used in such overall plan.” Sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs. A “material item” is “any item which involves the proper time for the inclusion of the item in income or the taking of a deduction.” Wayne Bolt & Nut Co. v. Commissioner, 93 T.C. 500, 510 (1989); sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs. A change in accounting method may be effected only after consent is obtained from the Secretary. See sec. 446(e). “The primary effect of characterizing a payment as either a business expense or a capital expenditure concerns the timing of the taxpayer’s cost recovery: While business expenses are currently deductible, a capital expenditure usually is amortizedPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011