- 33 - cases; the cases discussed above are those that most closely resemble the instant case. D. Conclusion We hold that petitioner must have respondent's consent under section 446(e) to change the year it reports payment of the bonuses. Petitioner does not have respondent's consent. Thus, petitioner may deduct its officers' bonuses only in the year in issue as it reported on its return. For the foregoing reasons, we conclude that petitioner is liable for the tax under section 1374(a) on the $929,915 net capital gain because the net capital gain is more than 50 percent of petitioner's taxable income. To reflect the foregoing and concessions, Decision will be entered under Rule 155.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33
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