- 8 - at 572-573. In Union Pac. R.R. Co. v. United States, supra at 1347-1348, the Court of Claims rejected the Commissioner’s attempt to distinguish Cincinnati. Petitioner contends that, like the taxpayers in Cincinnati and Union Pacific, its method of accounting clearly reflected its income within the meaning of section 446, and that respondent’s attempt to change petitioner’s accounting method was an abuse of discretion. Petitioner also contends that respondent cannot change its method of accounting because petitioner has consistently used an accounting method that clearly reflects income. 3. Comparison of Facts in Cincinnati, Union Pacific, and This Case The following chart compares petitioner to the taxpayers in Cincinnati and Union Pacific (to the extent a comparison can be made based on the record in this case and the Court of Claims’ opinions in Cincinnati3 and Union Pacific): Cincinnati Union Pacific Petitioner (1947, 1948 and 1949) (1942) (1995 and 1996) 1. Disputed Items Disputed $12,854 items 11,006 $467,944 24,715 $113,718 351,543 3 See Cincinnati, New Orleans & Tex. Pac. Ry. Co. v. United States, 191 Ct. Cl. 572, 600 (1970). The numerical data from Cincinnati can be found only in the Court of Claims reports.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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