- 35 - of reviewing the effects of petitioner’s recharacterization, such as adjusting for claimed depreciation, would defeat the accounting goal of promoting uniformity, to say nothing of the complex computations and inconvenience in administering the tax laws. Petitioner’s attempted recharacterization is precisely the type of change which frustrates the purpose of section 446(e) and renders the consent requirement necessary. V. Conclusion Petitioner consistently used a method of accounting of following regulatory rules and guidelines for regulatory, financial, and tax reporting purposes for the expenditures in issue. Petitioner’s attempt to alter its classification of the expenditures changes the timing of deductions related to those expenditures and thus is a change in the treatment of a material item. This change in treatment of a material item does not result from a correction or a change in underlying facts. Petitioner did not seek respondent’s consent, nor did respondent impliedly consent or waive the right to challenge petitioner’s recharacterization as an impermissible change of accounting method. Petitioner’s claimed recharacterization frustrates the purpose of section 446(e). Accordingly, we hold that petitioner’s attempted recharacterization of the expenditures inPage: 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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