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consistent application of generally accepted accounting
principles in a particular trade or business, is in accordance
with accepted conditions or practices in that trade or business,
and provides that all items of gross income and expenses are
treated consistently from year to year. Sec. 1.446-1(a)(2),
Income Tax Regs. A taxpayer’s method of accounting is generally
acceptable where the method is in compliance with the underlying
regulations of the Code. Sec. 1.446-1(c)(1)(ii)(C), Income Tax
Regs.; see, e.g., Frysinger v. Commissioner, 645 F.2d 523 (5th
Cir. 1981), affg. T.C. Memo. 1980-89; RLC Indus. Co. v.
Commissioner, supra; Van Raden v. Commissioner, 71 T.C. 1083
(1979), affd. 650 F.2d 1046 (9th Cir. 1981). “[I]f the taxpayer
succeeds in showing that the method it chose clearly reflects its
income, then respondent does not have discretion to disturb that
choice.” Peninsula Steel Prods. & Equip. Co. v. Commissioner, 78
T.C. 1029, 1045 (1982); see Photo-Sonics, Inc. v. Commissioner,
357 F.2d 656, 658 n.1 (9th Cir. 1966), affg. 42 T.C. 926 (1964);
Bay State Gas Co. v. Commissioner, 75 T.C. 410, 417, 423 (1980),
affd. 689 F.2d 1 (1st Cir. 1982). Petitioner maintains that its
method of expensing the cost of the garments and dust control
items when placed in service clearly reflects the income and
expenses of its industrial laundry business because the method
reflects the consistent application of generally accepted
accounting principles, the method is an accepted practice in the
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