9 the Commissioner, revoke or amend it merely because events do not unfold as planned. See, e.g., J.E. Riley Inv. Co. v. Commissioner, 311 U.S. 55 (1940); Pacific Natl. Co. v. Welch, 304 U.S. 191 (1938). Subject to a few narrow exceptions, "once the taxpayer makes an elective choice, he is stuck with it." Roy H. Park Broadcasting, Inc. v. Commissioner, 78 T.C. 1093, 1134 (1982). In Pacific Natl. Co., "often regarded as the fundamental authority for the development" of the doctrine of election, Estate of Stamos v. Commissioner, 55 T.C. 468, 473 (1970), the taxpayer had the option to treat certain income under the deferred payment or installment method. It reported the income using one method and later sought a refund based on a computation under the other method. The Supreme Court refused to allow this, holding: Change from one method to the other * * * would require recomputation and readjustment of tax liability for subsequent years and impose burdensome uncertainties upon the administration of the revenue laws. * * * There is nothing to suggest that Congress intended to permit a taxpayer, after expiration of the time within which a return is to be made, to have his tax liability computed and settled according to the other method. * * * Pacific Natl. Co. v. Welch, supra at 194; see also Grynberg v. Commissioner, supra at 261 (quoting Estate of Stamos v. Commissioner, 55 T.C. 468, 473 (1970)); Estate of Wilbur v. Commissioner, 43 T.C. at 473, and cases cited therein.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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