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arguments. First, petitioner asserts that it was not "required"
to change its accounting method pursuant to section 1.481-
1(c)(5), Income Tax Regs. Second, petitioner alleges that Rev.
Proc. 92-20, 1992-1 C.B. 685, violates equal protection.
Section 1.481-1(c)(5), Income Tax Regs., provides that "A
change in the taxpayer's method of accounting required as a
result of an examination of the taxpayer's income tax return will
not be considered as initiated by the taxpayer." (Emphasis
supplied.) Both the regulations and Rev. Proc. 92-20, supra,
differentiate between accounting method changes initiated by the
taxpayer and those initiated by the Commissioner. The year of
change is more favorable if the change is initiated by the
taxpayer.
Petitioner asserts the following: During the audit, the IRS
suggested petitioner be treated as a warranty company. In
response, petitioner proposed, as a compromise, that it be
treated as an insurance company. According to petitioner, that
compromise was accepted by respondent via the technical advice
memorandum. Because it was a "compromise", petitioner argues
that "there was no requirement that petitioner change accounting
methods." Petitioner's Opening Brief, p. 9.
Despite the spin petitioner attempts to place on events,
nothing in the record indicates that petitioner initiated any of
the events relating to its change of accounting method. The
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