- 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