- 27 - business practices. Petitioner’s treatment of the garments and dust control items as consumable materials and supplies and petitioner’s method of deducting the costs of these items in the taxable year that they were placed in service are consistent with the regulations, section 1.162-3, Income Tax Regs. See sec. 1.466-1(c)(1)(ii)(C), Income Tax Regs. We also conclude that petitioner has demonstrated that its method of expensing the garments and dust control items when placed in service results in a clear reflection of income under section 446 and section 1.446-1(a)(2), Income Tax Regs. Several factors influence our decision. For more than 30 years, petitioner’s taxable income was computed under the same method of accounting that petitioner used to compute its income for financial accounting. See sec. 446(a). Petitioner has also consistently used the same method for tax purposes since 1968, when it changed its method in response to an examination conducted by respondent. See Rev. Rul. 69-81, 1969-1 C.B. 137 (the deducting of rental items when placed in service is an acceptable method of accounting for Federal income tax purposes where an industrial laundry using the accrual method of accounting is engaged in the rental service of towels, garments, gloves, linens, and business shirts that have a useful life of 12 months or less); see also sec. 446(b); Ansley-Sheppard-BurgessPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011