- 26 -
method, as contemplating the use of accounting records, rather
than tax returns, to carry the taxpayer's burden. Sec. 1.481-
2(b), Income Tax Regs. We accordingly find that petitioners have
failed to introduce sufficient evidence to establish their
entitlement to the benefits of section 481(b)(2).
To reflect the foregoing and concessions,
Decision will be entered
under Rule 155.
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