Chen C. and Victoria R. Wang, et al. - Page 14

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          installment method to report income for tax purposes from the               
          sales of land.  In the notices of deficiency issued to EIC for              
          the taxable years 1989 through 1992, and to the Wangs for 1990,             
          respondent determined that the installment method was an imper-             
          missible method of accounting for tax purposes, and determined              
          that the accrual method was one that clearly reflected income.              
          Petitioner and EIC argue that the installment method is proper,             
          and therefore respondent improperly changed their accounting                
          method from one that clearly reflected income.                              
               Section 446(a) requires a taxpayer to compute taxable income           
          under the method of accounting it regularly uses in keeping its             
          books.  Section 446(b), however, provides that, if the method of            
          accounting regularly utilized by the taxpayer does not clearly              
          reflect taxable income, the computation of taxable income shall             
          be made under such method as, in the Commissioner's opinion, does           
          clearly reflect income.  The Commissioner's authority under                 
          section 446(b) reaches not only overall methods of accounting but           
          also a taxpayer's method of accounting for specific items of                
          income and expense.  Ford Motor Co. v. Commissioner, 102 T.C. 87,           
          100 (1994), affd. 71 F.3d 209 (6th Cir. 1995); sec. 1.446-1(a),             
          Income Tax Regs.                                                            
               It is well recognized that section 446 grants the Commis-              
          sioner broad discretion in matters of accounting and gives the              
          Commissioner wide latitude to adjust a taxpayer's method of                 





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