- 24 - change in method of accounting to comply with the UNICAP rules] shall be considered as using an improper method of accounting under the Code”). Because the subject year is the first taxable year in which taxable income is computed under a method of accounting that is different from the method of accounting used in the prior year, we agree with respondent that the subject year is the “year of change” for purposes of section 481. See also sec. 1.481-1(a)(1), Income Tax Regs. All arguments not discussed herein are either irrelevant or without merit. To reflect concessions, Decision will be entered under Rule 155.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Last modified: May 25, 2011