- 29 - 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.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
Last modified: May 25, 2011