Brookshire Brothers Holding, Inc. and Subsidiaries - Page 9

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               proper timing of an item, and is to be treated as a change             
               in method of accounting.  [Sec. 1.446-1(e)(2)(ii)(b), Income           
               Tax Regs.]                                                             
               Once a change in method of accounting is identified, the               
          procedures for securing the Commissioner’s consent are contained            
          in section 1.446-1(e)(3), Income Tax Regs.  To secure such                  
          consent, the taxpayer must “file an application on Form 3115 with           
          the Commissioner” or, alternatively, must comply with any                   
          administrative procedures the Commissioner might prescribe for              
          permitting certain types of changes in accounting method.  Id.              
               B.  Depreciation Deductions                                            
               Depreciation deductions are primarily governed by sections             
          167 and 168.  In relevant part, section 167 provides:                       
               SEC. 167.  DEPRECIATION.                                               
                    (a) General Rule.--There shall be allowed as a                    
               depreciation deduction a reasonable allowance for the                  
               exhaustion, wear and tear (including a reasonable                      
               allowance for obsolescence)--                                          
                         (1) of property used in the trade or                         
                    business, or                                                      
                         (2) of property held for the production of                   
                    (b) Cross Reference.--                                            
                    For determination of depreciation deduction in                    
               case of property to which section 168 applies, see                     
               section 168.                                                           
               Section 168, in turn, describes a specific depreciation                
          system for tangible property.  Section 168 was added to the                 
          Internal Revenue Code by the Economic Recovery Tax Act of 1981,             

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