Suzy's Zoo - Page 24




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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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Last modified: May 25, 2011