underlying payment in income, it effectively changed India Music’s treatment of a material item. We agree. From 1998 to 2004, India Music accounted for the accounts payable owed to HRI on an accrual basis, deducting the payments from income each year as they became fixed. But since HRI was a cash-basis taxpayer, it could not include the payments from India Music in its income until it received those payments. See Arnwine v. Comm’r, 696 F.2d 1102, 1111 ( nge in accounting method for the purposes of § 481 because it forced India Music to “com-put[e]” its taxable income for the tax year 2004 “under a method of accounting different from the method under which [India Music’s] taxable income for the preceding taxable year was computed.” 26 U.S.C. § 481; see Graff Chevrolet, 343 F.2d at 572 (<HOLDING>). Therefore, we find that the language of §§
holding that a change in the method of compensation met the consideration requirement of contract formation holding that a permanent change in income constitutes a substantial change in circumstances justifying a reduction of alimony holding that a change of venue has no affect on the applicable state law and that change of venue is but a change of courtrooms holding that  481 authorizes necessary adjustments to income in the year of change whether the change in method of accounting was initiated by the taxpayer or the commissioner holding that tolling inappropriate where data supplied to fund reflected change in accounting method which was central to dispute