Pelaez and Sons, Inc. - Page 23




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          that should have been capitalized under section 263A.  Our                  
          holding sustains respondent’s position that the corporation must            
          use capitalization principles, beginning in 1992, to account for            
          the expenditures of developing its trees.  Unless a section 481             
          adjustment is made, the amounts already deducted for the 1991               
          year as development costs of the 1989 and 1991 trees would in               
          effect be deductible a second time, in 1992 and later years, if             
          not through depreciation, then as accumulated costs set off                 
          against the proceeds realized from the sale of fruit grown on               
          these trees.                                                                
               Petitioner does not question respondent’s authority to make            
          the adjustment under section 481 but argues that there has not              
          been a change in the accounting method that would make section              
          481 available to respondent.  Without section 481, petitioner               
          contends that respondent is time barred from adjusting the 1992             
          taxable year.  Accordingly, we must decide whether respondent, by           
          requiring the corporation to capitalize such costs under section            
          263A for 1992 and future years, has changed the corporation’s               
          method of accounting for such costs.                                        
               Respondent relies on the definition for change of accounting           
          method contained in Rev. Proc. 92-20, 1992-1 C.B. 688, as                   
          follows:                                                                    
                    Section 1.446-1(e)(2)(ii)(a) of the regulations                   
               provides that a change in method of accounting includes                
               a change in the overall plan of accounting for gross                   
               income or deductions, or a change in the treatment of                  





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