Color Arts, Inc., John P. Csepella, A Person Other Than The Tax Matters Person - Page 14




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          erroneous method of accounting for vacation pay since at least              
          1994.9  Since the record is silent, we assume that on its 1994              
          return Color Arts also prematurely claimed a deduction for                  
          vacation pay which (under the corrected method) should have been            
          claimed on its 1995 return.  On its 1995 return, Color Arts                 
          prematurely claimed a $271,671.04 deduction for vacation pay.               
          Respondent examined only Color Arts’s 1996 return.10  Respondent            
          concluded, and petitioner agrees, that the $245,000 deduction for           
          accrued vacation pay claimed by Color Arts on its 1996 return               
          should have been claimed on Color Arts’s 1997 return.                       
               The record demonstrates that Color Arts consistently claimed           
          a deduction for vacation pay a year before its proper accrual,              
          and there is no evidence that any vacation pay deductions are               
          lost by the imposition of the section 481(a) adjustment.                    
          However, the failure to impose such an adjustment will allow                
          Color Arts to keep the $271,671.04 deduction it claimed in 1995             
          in addition to the $271,671.04 deduction in 1996.                           
          Conclusion                                                                  
               We hold that Color Arts’s method of accounting for its                 
          vacation pay has been changed.  Color Arts is entitled to a                 


               9The record does not indicate how long Color Arts has                  
          employed the erroneous method of premature deduction.  Given our            
          reasoning, infra, we do not think this absence is of substantive            
          significance.                                                               
               10See supra note 3.                                                    





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