- 29 - 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 taxablePage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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