Bank One Corporation - Page 107

                                        -188-                                         
          see Department of the Treasury, General Explanation of the                  
          President’s Budget Proposals Affecting Receipts 89-90 (Jan. 30,             
          1992), overlapped the G-30’s preparation of the G-30 report and             
          was released only a few months after the Treasury Department                
          published section 1.446-4, Proposed Income Tax Regs., supra, and            
          released its 1991 report, Modernizing the Financial System:                 
          Recommendations for Safer, More Competitive Banks (Feb. 1991).              
               In describing the reasons for section 475, both Congress and           
          the President emphasized that the change in tax accounting rules            
          would simply move tax accounting to the already accepted                    
          financial accounting treatment.  H. Rept. 103-111, supra at 661,            
          1993-3 C.B. at 237 (“Inventories of securities generally are                
          easily valued at year end, and, in fact, are currently valued at            
          market by securities dealers in determining their income for                
          financial statement purposes.”); see also Department of the                 
          Treasury, General Explanation of the President’s Budget Proposals           
          Affecting Receipts 36 (Feb. 25, 1993); Department of the                    
          Treasury, General Explanation of the President’s Budget Proposals           
          Affecting Receipts 89-90 (Jan. 30, 1992).  Congress also                    
          expressed its expectation “that the Treasury Department will                
          authorize the use of valuation methods that will alleviate                  
          unnecessary compliance burdens for taxpayers and clearly reflect            
          income for Federal income tax purposes”, H. Conf. Rept. 103-213,            
          supra at 616, 1993-3 C.B. at 494, thus implying that the                    






Page:  Previous  178  179  180  181  182  183  184  185  186  187  188  189  190  191  192  193  194  195  196  197  Next

Last modified: May 25, 2011