In Hyatt Hotels Corp. v. Commissioner, T.C. Memo. 2023-122, the Tax Court determined a taxpayer’s treatment of income and expenses related to its customer loyalty program did not implicate timing and, therefore, was not a method of accounting. Because the taxpayer’s existing tax treatment was not a method of accounting, the Commissioner could not invoke section 481(a) to require adjustments related to closed tax years, which adjustments gave rise to the lion’s share of the proposed deficiencies. This Alert discusses the court’s opinion in Hyatt as it relates to the method of accounting issue, and the implications of the court’s holding.
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