FPL Group, Inc. - Page 19




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          larger than the amount determined under the approximation method            
          previously used by the taxpayer.  See id. at 512.  We held that             
          the taxpayer’s “change from a seriously flawed and disorganized             
          method * * * to a method of determining both opening and ending             
          inventory * * * on the basis of a complete physical inventory               
          [was] a change in the treatment of a material item and,                     
          therefore, [constituted] a change in accounting method.”  Id. at            
          510.  We found that the approximation method of determining                 
          inventory, while disorganized and inaccurate, was consistently              
          used by the taxpayer despite his actual knowledge that the                  
          inventory amounts were not completely accurate.  See id. at 512.            
          This consistent practice constituted a method of accounting for             
          determining inventory.  See id.                                             
               Petitioner argues that Wayne Bolt & Nut Co. v. Commissioner,           
          supra, does not apply because it involved inventories and they              
          are governed by separate and distinct rules for purposes of                 
          determining a method of accounting.  We disagree.  While there              
          are specific regulations which address the accounting treatment             
          of inventories, the basic principles apply for purposes of                  
          determining a method of accounting; namely, that a consistent               
          method used to determine the tax treatment of a material item is            
          a method of accounting.  Our holding and reasoning in Wayne Bolt            
          & Nut Co. v. Commissioner, supra, is applicable to the instant              
          case.                                                                       






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