- 10 - completion method for financial statement purposes and used the cash method of accounting for income tax purposes. Petitioner did not file a Form 3115 (Application for Change in Accounting Method) or otherwise seek respondent's approval to change its method of accounting. See sec. 1.446-1(e)(3)(i), Income Tax Regs. Section 446(e) provides that a taxpayer generally is required to secure the Commissioner's consent before changing its method of accounting. See sec. 1.446-1(e)(2)(i), Income Tax Regs. Further, section 1.446-1(e)(2)(ii)(a), Income Tax Regs., provides that a change from the accrual method to the cash method of accounting is a change in a taxpayer's method of accounting. In view of petitioner's failure to obtain consent from respondent before changing its method of accounting, we sustain as a matter of law respondent's determination that petitioner must use the accrual method of accounting for its taxable years ending January 31, 1989 and 1990. In order to reflect the foregoing, An order granting respondent's Motion for Summary Judgment and decision for respondent will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10
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