Prudential Overall Supply - Page 27




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          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-Burgess           








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