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deficiency of Rev. Proc. 84-74, 1984-2 C.B. 736. That revenue
procedure had been used by a number of taxpayers to request a
change in a later year and on better terms than those contained
in the statute. In other words, a taxpayer, even if aware that
its accounting method did not clearly reflect income, could apply
for a method change, and, in doing so, receive better terms than
if the IRS had mandated the change. Rev. Proc. 92-20, 1992-1
C.B. at 688.
Petitioner has stipulated that it should be following the
method of accounting described in section 832. Petitioner
further stipulated that its method of accounting was not in
accordance with section 832(b)(4). As a result, its method did
not clearly reflect income. However, if petitioner is allowed to
use 1993 as the year of change, it will be allowed to knowingly
use an incorrect method for 3 years. This is the situation Rev.
Proc. 92-20, supra, was implemented to prevent.
Petitioner alludes to various sections of the revenue
procedure to bolster its claim that its year of change should be
1993. These sections do not apply to petitioner for the simple
reason that petitioner was under examination.
The Commissioner is given broad authority to determine
whether a taxpayer's accounting method clearly reflects income.
That determination "is not to be set aside unless it is shown to
be plainly arbitrary or an abuse of discretion." Gustafson v.
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