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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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