- 92 - V. Clear Reflection of Income A. Introduction By characterizing the printing, telephone, computer, rent, and utilities costs here in question as overhead, petitioner and the majority do no more than identify that allocation is required. In concluding that such costs need not be capitalized, the majority accepts without question ACC’s allocation, which allocates the costs to ACC’s postacquisition and servicing activities (for which an immediate deduction is available). The majority fails to apply any criteria to its acceptance of ACC’s allocation. Notwithstanding that such allocation may be acceptable (even required) for financial accounting purposes, see majority op. p. 12 note 9, it still involves a method of accounting. For Federal income tax purposes, 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.” Sec. 1.446-1(a)(1), Income Tax Regs.; see also sec 1.446- 1(e)(2)(ii)(a), Income Tax Regs. (a change in method of accounting includes any change in the treatment of any “material item”: “A material item is any item which involves the proper time for the inclusion of the item in income or the taking of a deduction.” (Emphasis added.)). A taxpayer’s method of accounting must clearly reflect income or the Secretary may require the computation of taxable income under a method ofPage: Previous 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 Next
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