Sunoco, Inc. and Subsidiaries - Page 42

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             method that is subject to section 446(e), then the taxpayer              
             is foreclosed from making the change by section 446(e) and               
             the regulations promulgated thereunder without regard to                 
             whether the new method would be proper.  See So. Pac.                    
             Transp. Co. v. Commissioner, supra at 682; Wright                        
             Contracting Co. v. Commissioner, supra at 635-636.  The                  
             issue whether the change of accounting method is proper is               
             not pertinent until after the Commissioner has refused the               
             taxpayer’s request for consent to the change.  See Brown                 
             v. Helvering, supra at 203; Wright Contracting Co. v.                    
             Commissioner, supra at 636; Advertisers Exchange, Inc.,                  
             v. Commissioner, 25 T.C. at 1093.                                        

             Meaning of the Phrase “Method of Accounting”                             
                  The Code does not define the phrase “method of                      
             accounting”.  We have held that the phrase includes “the                 
             consistent treatment of any recurring, material item,                    
             whether that treatment be correct or incorrect.”  See Bank               
             One Corp. v. Commissioner, 120 T.C. 174, 282 (2003); H.F.                
             Campbell Co. v. Commissioner, 53 T.C. 439, 447 (1969),                   
             affd. 443 F.2d 965 (6th Cir. 1971).                                      
                  The regulations promulgated under section 446 state:                
             “The term ‘method of accounting’ includes not only the                   
             over-all method of accounting of the taxpayer but also the               
             accounting treatment of any item.”  Sec. 1.446-1(a)(1),                  





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