- 45 - deducted as business expenses, but which are in fact personal expenses, are not changes in method of accounting. * * * A change in the method of accounting also does not include a change in treatment resulting from a change in underlying facts. On the other hand, for example, a correction to require depreciation in lieu of a deduction for the cost of a class of depreciable assets which had been consistently treated as an expense in the year of purchase involves the question of the proper timing of an item, and is to be treated as a change in method of accounting. The Change That Petitioner Seeks To Make in This Case Involves a Material Item In the present case, petitioner is not seeking to change its overall plan of accounting for gross income or deductions, such as by changing from the accrual method to some other overall method of accounting. Rather, the change that petitioner seeks to make involves the treatment of a single item, the overburden removal costs incurred by Cordero at the Gillette mine, which forms a part of petitioner’s overall plan. We must determine whether this is a material item; that is, an “item which involves the proper time for the inclusion of the item in income or the taking of a deduction.” See sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs. If it is a material item, then a change in its treatment can involve a change in petitioner’s method of accounting, and we must consider petitioner’s other arguments.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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