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insurance expense, since this condition, as discussed more fully
below, does no more than require adherence to existing
regulations. We think the Commissioner’s broad discretion to
determine whether a method of accounting clearly reflects income
under section 446(b), see Thor Power Tool Co. v. Commissioner,
439 U.S. 522 (1979); Commissioner v. Hansen, 360 U.S. 446, 467
(1959), coupled with the requirement in section 446(e) that the
Commissioner’s consent be secured for any change in method,
encompasses the authority to impose the condition at issue
herein.
Petitioners’ argument that their method of accounting for
insurance expense produces superior matching of income and
related expense is unavailing. Matching of income and related
expense does not necessarily result in a clear reflection of
income for tax purposes. See Thor Power Tool Co. v.
Commissioner, supra at 543. A prepayment for services to be
performed in the future must be recognized when received, even
though this would mismatch expenses and revenues. See American
Auto. Association v. United States, supra; Automobile Club of
Michigan v. Commissioner, supra. Absent Rev. Proc. 92-98,
supra, existing law would require an even greater mismatch of EWA
income and associated insurance expense than the “distortion”
that petitioners complain is produced by Rev. Procs. 92-98 and
92-97, supra. Existing law would require the recognition of the
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