- 2 - Commissioner v. Brookshire Bros. Holding, Inc. & Subs., ___ F.3d ___ (5th Cir., Jan. 29, 2003), affg. T.C. Memo. 2001-150, followed. Robert J. Gumser, for petitioner. Yvonne M. Peters, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION NIMS, Judge: Respondent determined Federal income tax deficiencies for petitioner’s tax fiscal years ended in August 1996, August 1997, and August 1998, in the amounts of $147,277, $31,983, and $46,729, respectively. At trial, petitioner conceded that the modified accelerated cost recovery system (MACRS), alternative depreciation system rules, in accordance with section 168(g)(1), required petitioner to use a 10-year recovery period and the straight-line method of depreciation for items of petitioner’s equipment that were placed in service after 1986 and used predominantly outside of the United States. The issue for decision is whether a change in MACRS classification that results in a change in depreciation method and recovery period is a change in method of accounting for purposes of an adjustment pursuant to section 481(a).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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