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Regs., it is the consistent treatment of an item involving a
question of timing that establishes such treatment as a method of
accounting. Therefore, a short-lived deviation from an already
established method of accounting need not be viewed as establishing
a new method of accounting.19 If not so viewed, neither the
deviation from, nor the subsequent adherence to, the method of
accounting would be a change in method of accounting. The
question, of course, is what is short-lived. The Commissioner’s
position is that consistency is established for purposes of section
1.446-1(e)(2)(ii)(a), Income Tax Regs., by the same treatment of a
material item in two or more consecutively filed returns. Rev.
Proc. 2002-18, 2002-1 C.B. 678. We have said something similar.
Johnson v. Commissioner, supra at 494. We need not today determine
how long is short. Here, even if we were to assume that the
members elected the link-chain method and adopted it, see supra pp.
46-48, no member deviated from the link-chain method for less than
10 years. That is not a short-lived deviation.
D. Conclusion
We affirm the conclusions that, tentatively, we reached supra
in section III.B. of this report. The accountant erred in applying
the link-chain method. He did so consistently, and his error was
an error in timing. It was not, within the meaning of section
19 Nor in reaching that conclusion would a court have to
find that the taxpayer committed a posting or mathematical error.
See sec. 1.446-1(e)(2)(ii)(b), Income Tax Regs.
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