Prudential Overall Supply - Page 16




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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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