- 11 - opening and ending inventory for fiscal year 1982 on the basis of a complete physical inventory [was] a change in the treatment of a material item and, therefore, constitutes a change in accounting method.” Id. at 511; accord Knight-Ridder Newspapers, Inc. v. United States, supra; Firetag v. Commissioner, T.C. Memo. 1999-355 (the Commissioner’s determination that the taxpayer had previously used an improper method of accounting which involved a systematic and consistent treatment of a significant item was not a computational or posting error but rather a change in his method of accounting), affd. 232 F.3d 887 (4th Cir. 2000). The Court of Appeals for the Seventh Circuit, to which this case is appealable, has decided a substantially similar case. In Peoples Bank & Trust Co. v. Commissioner, 415 F.2d 1341 (7th Cir. 1969), affg. 50 T.C. 750 (1968), the taxpayer was a calendar year, overall accrual method bank which paid interest on its savings accounts. Because of the interplay between when the taxpayer paid interest and its tax year, for 2 months of the year the taxpayer calculated its interest expense on the basis of a “fairly accurate” experience factor, although the interest was not payable until the following tax year. Like here, the interest expense failed the “all events test” the Commissioner corrected the taxpayer’s method, and imposed a section 481(a) adjustment. This Court agreed with the Commissioner and sustained his determination finding that the taxpayer’s method ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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