- 28 - 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 ofPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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