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opinion of the Commissioner, it clearly reflects income. Sec.
1.446-1(a)(2), Income Tax Regs. Thus, a prerequisite to the
Commissioner's requirement that a taxpayer change its present
method of accounting is a determination that the method used by
the taxpayer does not clearly reflect income. Sec. 446(b);
Hallmark Cards, Inc. v. Commissioner, 90 T.C. 26, 31 (1988).
Section 446 imposes a heavy burden on the taxpayer disputing the
Commissioner's determination on accounting matters. Thor Power
Tool Co. v. Commissioner, 439 U.S. 522, 532-533 (1979). To
prevail, a taxpayer must establish that respondent's
determination is "clearly unlawful" or "plainly arbitrary". Id.
However, if the taxpayer's method of accounting is specifically
authorized by the Code or the regulations thereunder and has been
applied on a consistent basis, the Commissioner is ordinarily not
permitted to reject the taxpayer's method, as not providing a
clear reflection of income, and require the use of another
method. Hallmark Cards, Inc. v. Commissioner, supra at 31;
Peninsula Steel Prods. & Equip. Co. v. Commissioner, 78 T.C.
1029, 1050 (1982). Furthermore, this Court has held that the
Commissioner cannot require a taxpayer to change from an
accounting method which clearly reflects income to an alternate
method of accounting merely because the Commissioner considers
the alternate method to more clearly reflect the taxpayer's
income. Molsen v. Commissioner, 85 T.C. 485, 498 (1985);
Peninsula Steel Prods. & Equip. Co. v. Commissioner, supra at
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