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accounting different from the method under which the taxpayer's
income for the preceding taxable year was computed, there shall
be taken into account those adjustments which are determined to
be necessary solely by reason of the change in order to prevent
an amount from being duplicated or omitted. Since we have held
that petitioner is not required to change from the cash method
for the taxable year at issue, petitioner's taxable income is
computed under the same method of accounting as in the previous
taxable year. Therefore, petitioner is not subject to any
adjustments under section 481.
III
Whether Petitioner Is Liable for the Accuracy-Related Penalty
Under Section 6662(a)
In its brief, petitioner addressed the accuracy-related
penalty only with respect to the change in accounting method.
Petitioner concedes that it is not entitled to deduct the loss
on the sale of an automobile. The deficiency to be computed
under Rule 155 is attributable solely to the disallowance of
that loss. Therefore, we hold petitioner is liable for the
accuracy-related penalty under section 6662(a).
To reflect the foregoing and because of the concessions by
the parties,
Decision will be entered
under Rule 155.
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