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Section 446(b) authorizes the Commissioner to exercise her
discretion with respect to tax accounting methods. As stated
therein, "if the method used [by the taxpayer] does not clearly
reflect income, the computation of taxable income shall be made
under such method as, in the opinion of the Secretary, does
clearly reflect income." Sec. 446(b); see also Thor Power Tool
Co. v. Commissioner, 439 U.S. 522 (1979). In general, a method
of accounting clearly reflects income when it accurately reports
taxable income under a recognized method of accounting.
Wilkinson-Beane, Inc. v. Commissioner, 420 F.2d 352, 354
(1st Cir. 1970), affg. T.C. Memo. 1969-79; RLC Indus. Co. v.
Commissioner, 98 T.C. 457, 490 (1992), affd. 58 F.3d 413 (9th
Cir. 1995); Rotolo v. Commissioner, 88 T.C. 1500, 1513 (1987).
Courts do not interfere with the Commissioner's discretion with
respect to accounting methods unless she has abused it. Thor
Power Tool Co. v. Commissioner, supra at 532; Lucas v. American
Code Co., 280 U.S. 445, 449 (1930); Ford Motor Co. v.
Commissioner, 102 T.C. 87, 92 (1994), affd. 71 F.3d 209 (6th Cir.
1995). Whether the Commissioner has abused her discretion is a
question of fact, Rodebaugh v. Commissioner, 518 F.2d 73, 75 (6th
Cir. 1975), affg. T.C. Memo. 1974-36, and her determination will
not be set aside unless it is shown to be "plainly arbitrary",
Thor Power Tool Co. v. Commissioner, supra at 533. Petitioner
must prove that the exercise of the Commissioner's discretion was
plainly arbitrary. Asphalt Prods. Co. v. Commissioner, 796 F.2d
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