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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.
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