- 7 - 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 postingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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