Brookshire Brothers Holding, Inc. and Subsidiaries - Page 13

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          as well as a change in the treatment of any material item.  See             
          sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs.  A material item, in            
          turn, is explained by regulations as “any item which involves the           
          proper time for the inclusion of the item in income or the taking           
          of a deduction.”  Id.  This Court has also expounded that “When             
          an accounting practice merely postpones the reporting of income,            
          rather than permanently avoiding the reporting of income over the           
          taxpayer’s lifetime, it involves the proper time for reporting              
          income.”  Wayne Bolt & Nut Co. v. Commissioner, 93 T.C. 500, 510            
               In the case at bar, petitioner altered neither its overall             
          plan of accounting for income and deductions on an accrual basis            
          nor its basic system of accounting for depreciation using MACRS.            
          Petitioner is, however, seeking to switch from deducting the cost           
          of its gas station properties over a 31.5- or 39-year period on a           
          straight line basis to writing off these costs over a 15-year               
          term on a declining balance basis.  Such involves the timing of             
          deductions, not the total amount of lifetime income, and would              
          thus appear at first blush to be a “material” difference                    
          signaling a change in accounting method.                                    
               Yet regulations specifically provide that “a change in the             
          method of accounting does not include * * * an adjustment in the            
          useful life of a depreciable asset”, notwithstanding the fact               
          that “such adjustments may involve the question of the proper               

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