- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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