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income is not affected. See Schuster’s Express, Inc. v.
Commissioner, supra; sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs.
Petitioners argue that the change in the timing of the
income was not a change in method of accounting, but it rather
was a correction in the proper application of the cash basis
method of accounting. Petitioners cite our opinion in Evans v.
Commissioner, T.C. Memo. 1988-228, for the proposition that a
taxpayer may correct an inadvertent mistake in the application of
its method of accounting without the correction’s constituting a
change in method of accounting. In Evans, the taxpayers earned
yearly bonuses which were authorized by their employer at annual
board meetings but paid in each of the years subsequent to each
of the meetings. The taxpayers historically had been including
bonuses in income in the year in which the bonuses were
authorized rather than the year in which they were received,
despite the fact that the taxpayers otherwise used the cash
method of accounting. The taxpayers had been relying on the
Forms 1099 issued to them by the corporation through its
accountant, who had no knowledge that the bonuses were received
in a year other than the year they were declared. We found that,
by changing the year of inclusion, the taxpayers did not
“consciously” adopt a new form of accounting other than their
overall cash method of accounting, and that the taxpayers were
merely correcting “inadvertent errors analogous to posting
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