- 28 - this case involves a change in the treatment of a material item; that is, “any item which involves the proper time for the inclusion of the item in income or the taking of a deduction.” Sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs. According to respondent, in determining whether an accounting practice for an item involves timing, “the relevant question is whether the practice permanently changes the taxpayer’s lifetime income.” Respondent argues that the change in petitioner’s treatment of Cordero’s overburden removal costs involves timing. The change is from development costs that are deductible under section 616(a) but subject to partial capitalization and amortization under section 291(b), to production costs that can be offset against income without limitation. Respondent argues that this change affects the tax years in which the deductions are reported over the life of the mine and does not affect petitioner’s lifetime income. Therefore, respondent argues, the change involves a material item under section 1.446-1(e)(2)(ii)(a), Income Tax Regs., and is a change of accounting method because the effect of the change would be to alter the timing of deductions for overburden removal costs. Respondent argues that the change goes beyond a mere correction of a posting error or an attempt to remedyPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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