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United States, 151 F.3d 876, 883 (8th Cir. 1998); sec. 1.446-
1(e)(2)(ii)(b), Income Tax Regs.
Petitioner does not contend that it made errors in
mathematical computations or in the computation of its tax
liability. Petitioner has failed to make specific allegations
establishing there was a change in underlying facts.
Under section 1.446-1(e)(2)(ii)(b), Income Tax Regs., a
change from capitalizing and depreciating the costs of a class of
depreciable assets to expensing them involves a question of
proper timing. Petitioner’s attempt to recharacterize
expenditures at Florida Power’s electric plants, which were
consistently capitalized on its tax returns, fits within the
principles of this regulatory provision. Although the instant
case is the reverse of the situation set forth in the regulatory
provision, we regard both situations as examples of changes
involving the timing of a deduction. See Southern Pac. Transp.
Co. v. Commissioner, 75 T.C. at 683 n.211. Additionally, this
Court has found that the characterization of expenditures as
capital or expense involves the proper time for taking a
deduction. See Pelaez & Sons, Inc. v. Commissioner, 114 T.C. at
489; Southern Pac. Transp. Co. v. Commissioner, supra at 683;
Hooker Indus., Inc. v. Commissioner, T.C. Memo. 1982-357.
A posting error occurs when there is an error in “the act of
transferring an original entry to a ledger.” Wayne Bolt & Nut
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