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which are determined to be necessary solely by reason of the
change in order to prevent an amount from being duplicated or
omitted. Section 481 was designed by Congress to prevent the
duplication or omission of income or expense that may otherwise
occur solely through a change in a method of accounting that is
used by a taxpayer to compute his or her taxable income. See
Graff Chevrolet Co. v. Campbell, 343 F.2d 568, 572 (5th Cir.
1965); Pursell v. Commissioner, 38 T.C. 263, 271 (1962), affd.
315 F.2d 629 (3d Cir. 1963). Congress designed section 481
broadly to allow the Commissioner to adjust income for a "year of
the change" by increasing that year's income by any income that
was earned in a "closed year" but went unreported due to the
mechanics of the taxpayer's old accounting method. See Graff
Chevrolet Co. v. Campbell, supra at 572. The year of change is
the first taxable year in which taxable income is computed under
a method of accounting that is different from the method of
accounting that was used in the prior year. See sec. 1.481-
1(a)(1), Income Tax Regs.
In accordance with this firmly established law, the year of
change in this case is the subject year; i.e., the first year in
which petitioner’s method of accounting was changed to reflect
the UNICAP rules. Petitioner attempts to distinguish this law by
arguing that, as of its first taxable year beginning in 1987, TRA
section 803(d)(2) changed its method of accounting to conform to
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