- 23 - 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 ofPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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