Dow A. and Sandra E. Huffman, et al. - Page 29

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               or basis used in the valuation of inventories * * *                    
          Sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs.  The regulations also           
          provide certain rules of exclusion; e.g.,                                   
               A change in method of accounting does not include                      
               correction of mathematical or posting errors, or errors                
               in the computation of tax liability (such as errors in                 
               computation of the foreign tax credit, net operating                   
               loss, percentage depletion or investment credit).  Also,               
               a change in method of accounting does not include                      
               adjustment of an item of income or deduction which does                
               not involve the proper time for the inclusion of the item              
               of income or the taking of a deduction.  For example,                  
               corrections of items that are deducted as interest or                  
               salary, but which are in fact payments of dividends, and               
               of items that are deducted as business expenses, but                   
               which are in fact personal expenses, are not changes in                
               method of accounting.  * * *                                           
          Sec. 1.446-1(e)(2)(ii)(b), Income Tax Regs.  The regulations give           
          no guidance as to the meaning of the term “mathematical error”.             
               B.  Section 481                                                        
               The distinction between a change in method of accounting and           
          the correction of a mathematical error is especially significant            
          because of section 481.  “Section 481 prescribes the rules to be            
          followed in computing taxable income in cases where the taxable             
          income of the taxpayer is computed under a method of accounting             
          different from that under which the taxable income was previously           
          computed.”  Sec. 1.481-1(a)(1), Income Tax Regs.  For purposes of           
          section 481, a change in method of accounting includes a change in          
          the taxpayer’s overall method of accounting or a change in the              
          taxpayer’s treatment of a material item.  See id.  Section 481(a)           
          specifies that, in computing the taxpayer’s income for the taxable          





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