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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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