Mid Del Therapeutic Center, Inc. - Page 17

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            to be 'plainly arbitrary.'"  Id. at 532-533 (quoting Lucas v.                              
            Kansas City Structural Steel Co., 281 U.S. 264, 271 (1930)).                               
            The Commissioner's determination that a taxpayer's method of                               
            accounting does not clearly reflect its income is given great                              
            deference by this Court, but the Commissioner may not require a                            
            taxpayer to change from an accounting method which clearly                                 
            reflects income to an alternate method of accounting merely                                
            because the Commissioner considers the alternate method to more                            
            clearly reflect the taxpayer's income.  See Ansley-Sheppard-                               
            Burgess Co. v. Commissioner, supra at 371.                                                 
                  The issue of whether the taxpayer's method of accounting                             
            clearly reflects income is a question of fact to be determined on                          
            a case-by-case basis.  See id.  In reviewing the Commissioner's                            
            determination that the taxpayer's method of accounting does not                            
            clearly reflect income, the function of the Court is to determine                          
            whether there is an adequate basis in law for the Commissioner's                           
            conclusion.  See RCA Corp. v. United States, 664 F.2d 881, 886                             
            (2d Cir. 1981).  Consequently, to prevail, a taxpayer must prove                           
            that the Commissioner's determination was arbitrary, capricious                            
            or without sound basis in fact or law.  See Knight-Ridder                                  
            Newspapers, Inc. v. United States, supra; Ansley-Sheppard-Burgess                          
            Co. v. Commissioner, supra.                                                                
                  Sec. 471(a) provides:                                                                
                  SEC. 471.  GENERAL RULE FOR INVENTORIES.                                             
                        (a) General Rule.--Whenever in the opinion of the                              
                  Secretary the use of inventories is necessary in order                               

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