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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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