Toyota Town, Inc. - Page 16





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          accounting9 from one that clearly reflects income to a method               
          that distorts income, or, alternatively, that the qualified                 
          advance payment amounts should be fully deductible in the year              
          paid to Western General.  We consider each in turn.                         
               B. Abuse of Discretion                                                 
                    1. In General                                                     
               Petitioners contend that respondent’s effort to limit their            
          amortization deduction for insurance costs to a pro rata portion            
          of the premium in the first year, measured by the portion of the            
          year for which the policy was actually in force, constitutes an             
          abuse of discretion.  In petitioners’ view, the method of                   
          accounting for insurance costs for multiyear policies that they             
          employed, which involved deducting a full year’s worth of premium           
          in the first year, regardless of the actual date of commencement            
          of coverage, effects a clear reflection of income because it more           
          closely matches expense with associated income-–given the                   
          requirement of Rev. Proc. 92-98, 1992-2 C.B. 512, that the                  
          corresponding income be recognized under a convention that treats           
          it as received on the first day of the year without regard to               
          actual receipt.  The method sought by respondent, petitioners               


               9 The parties do not dispute that the timing of petitioners’           
          deductions for the amounts paid to Western General constitutes a            
          “method of accounting” within the meaning of sec. 446.  See sec.            
          1.446-1(a)(1), Income Tax Regs. (“The term ‘method of accounting’           
          includes not only the over-all method of accounting of the                  
          taxpayer but also the accounting treatment of any item.”).                  





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