FPL Group, Inc. - Page 18




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          the Commissioner had not consented to the change.  See id. at               
          680.  We held that, regardless of whether the expenditures were             
          more properly deductible as business expenses under section 162,            
          allowing the taxpayer to deduct such expenditures would result in           
          an impermissible change in method of accounting.  See id. at 687.           
          We found it readily apparent that the taxpayer was seeking to               
          alter the manner in which it had consistently accounted for a               
          recurring, material item.  See id. at 686.  We explained that a             
          change in the treatment of the expenditures involved a question             
          of proper timing; thus, the change in treatment would affect a              
          material item.  See id. at 683.  The taxpayer consistently                  
          followed the ICC accounting rules in capitalizing certain                   
          expenditures for tax reporting purposes, and its later attempt to           
          recharacterize those expenditures as repair expenses was                    
          prohibited, absent consent by the Commissioner.                             
               In Wayne Bolt & Nut Co. v. Commissioner, 93 T.C. 500 (1989),           
          the taxpayer, for a number of years, determined its ending                  
          inventory by selecting a small portion of its inventory cards and           
          using them to approximate the ending inventory.  See id. at 503.            
          Later, the taxpayer completed a physical inventory in which it              
          identified and catalogued all inventory.  See id. at 504.  Based            
          on this thorough examination of inventory, the taxpayer attempted           
          to adjust its opening inventory to reflect the actual amount                
          identified.  See id. at 504-505.  This amount was considerably              






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