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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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