- 8 -
respondent's acquiescence in prior audits to a taxpayer's
accounting method may be considered in determining whether she is
justified in changing that method currently, Public Serv. Co. v.
Commissioner, 78 T.C. 445, 456 (1982), we reject petitioner's
attempt to prevent respondent from changing its erroneous method
of accounting under the facts herein. See Ezo Prods. Co. v.
Commissioner, 37 T.C. 385, 391 (1961); see also Thomas v.
Commissioner, 92 T.C. 206, 225-226 (1989). We hold for
respondent. In so holding, we have considered all of
petitioner's arguments for a contrary holding and, to the extent
not addressed above, find them to be irrelevant or without
merit.4
To reflect concessions,
Decisions will be entered
under Rule 155.
4 In particular, we note that we have rejected petitioner's
argument concerning an abuse of discretion. Simply stated,
respondent's determination is within the broad discretion that
she is afforded with respect to matters of tax accounting. See,
e.g., Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 532-533
(1979); Commissioner v. Joseph E. Seagram & Sons, Inc., 394 F.2d
738, 743 (2d Cir. 1968), revg. 46 T.C. 698 (1966); Thomas v.
Commissioner, 92 T.C. 206, 220 (1989).
Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011