Golden Gate Litho - Page 28

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               By contrast, in this case proper application of the                    
          accrual method and inventory valuation would require a full                 
          audit of petitioner's books and records.  The record does                   
          not provide any basis upon which the Court can properly value               
          petitioner's inventory or accounts receivable and payable or                
          otherwise discern petitioner's taxable income under a proper                
          accrual method.  In this case, the erroneous items cannot be                
          discerned with relative clarity and, therefore, cannot be                   
          corrected in a computation under Rule 155.  Cf. All-Steel                   
          Equip. Inc. v. Commissioner, 54 T.C. 1749 (1970), affd. in                  
          part, revd. in part and remanded 467 F.2d 1184 (7th Cir. 1972).             
          The Internal Revenue Code contemplates action by the                        
          Commissioner, not the courts.  Harden v. Commissioner, supra at             
          421.                                                                        
               Since petitioner's cash method is a rational system, we                
          think that the Court may choose to let it stand.  We see no                 
          basis for placing a greater burden on the Court than we place               
          on the Commissioner.  See Estate of Sperling v. Commissioner,               
          supra at 203.  We hold that petitioner is not required to                   
          change from the cash method of accounting for the taxable year              
          at issue.                                                                   
                                         II                                           
          Whether Respondent's Adjustments Under Section 481 Were Proper              
               Section 481(a)(1) provides that where in computing a                   
          taxpayer's taxable income the computation is under a method of              



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