Bank One Corporation - Page 84

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          correct this problem.  The Court held that this correction was a            
          change in the method of accounting that, under section 481,                 
          required the taxpayer to recapture in income the cost of items              
          mistakenly written off in prior years.  Id. at 513.  In Primo               
          Pants Co. v. Commissioner, supra, the taxpayer consistently                 
          valued its inventories as a percentage of cost when its                     
          inventories should have been valued at full cost.  The Court held           
          that deferral of income until final closing inventory was                   
          corrected was a timing question that constituted a change in                
          accounting method.  Id. at 725; accord Dearborn Gage Co. v.                 
          Commissioner, 48 T.C. 190, 197-198 (1967) (concluding that the              
          exclusion of overhead costs in valuing inventory is an erroneous            
          method of accounting involving a material item); Hitachi Sales              
          Corp. of Am. v. Commissioner, T.C. Memo. 1994-159 (a change from            
          an improper method of valuing inventory to a proper valuation               
          method is a change in method of accounting), supplemented T.C.              
          Memo. 1995-84.                                                              
               We find in the legislative history under section 475 further           
          support for our conclusion that the instant issue involves a                
          method of accounting.  That history, although considered to be              
          secondary when interpreting the statutory text, is most useful              
          when it comes to discerning a statute’s intended purpose.  Bob              
          Jones Univ. v. United States, 461 U.S. 574, 586 (1983);                     
          Albertson’s, Inc. v. Commissioner, 42 F.3d 537, 541 (9th Cir.               






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