- 19 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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