- 42 - 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),Page: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
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