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a net operating loss of $37,636 for the taxable year ending May
31, 1992. Under the circumstances of this case, and given the
inadequacies of respondent's method, we think petitioner's use
of the cash method produces substantially the same results.
Furthermore, respondent's method not only distorts
petitioner's income but will subject petitioner to further
adjustments, including adjustments under section 481, in
subsequent taxable years if petitioner attempts to properly
comply with regulations for accrual method accounting. If, in
respondent's opinion, petitioner's accounting method did not
clearly reflect its income, the remedy was to require a
computation on a basis that would correctly reflect income by
proper application of the accrual method of accounting.
The fact that the Commissioner possesses broad authority
under section 446(b) does not mean that the Commissioner can
change a taxpayer's method of accounting with impunity. See
Prabel v. Commissioner, 91 T.C. 1101, 1112-1113 (1988), affd.
882 F.2d 820 (3d Cir. 1989); Wal-Mart Stores, Inc. v.
Commissioner, T.C. Memo. 1997-1. The Commissioner cannot
require a taxpayer to change his accounting method to one which
is unacceptable or wrong. Harden v. Commissioner, 223 F.2d
418, 421 (10th Cir. 1955), revg. and remanding 21 T.C. 781
(1954); Rotolo v. Commissioner, 88 T.C. at 1514. Courts will
not approve the Commissioner's change of a taxpayer's
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