- 28 - 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 & NutPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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