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if improper, would either accelerate or postpone the recognition
of that income. See Knight-Ridder Newspapers, Inc. v. United
States, 743 F.2d 781 (11th Cir. 1984).
Our conclusion is further supported by a line of cases under
section 481 dealing with inventory. Those cases are pertinent in
that FNBC’s swaps are analogous to inventory and section 481
defers to section 446(e) to define a change in method of
accounting. Three of the seminal cases are Hamilton Indus. Inc.
v. Commissioner, 97 T.C. 120 (1991), Wayne Bolt & Nut Co. v.
Commissioner, supra, and Primo Pants Co. v. Commissioner, 78 T.C.
705 (1982). In Hamilton Indus. Inc. v. Commissioner, supra, the
taxpayer attempted to shield the recognition of gain on inventory
acquired in a bargain purchase by treating that inventory and
subsequently acquired raw materials and manufactured goods as a
single item of inventory under the LIFO method. The Court
concluded that this practice was unacceptable for tax purposes
and constituted a change in method of accounting. Id. at 127.
In Wayne Bolt & Nut Co. v. Commissioner, supra, the taxpayer had
used for a number of years a sampling method for determining the
value of its ending inventory. When the taxpayer actually took a
complete physical count of its inventory, it discovered that
approximately $2 million worth of inventory that had been
previously written off was actually still in inventory. The
taxpayer increased its opening and ending inventories in order to
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