- 7 - pursuant to section 1.466-1(c)(2)(i), Income Tax Regs., to reflect accurately the income of its business activities. Petitioner maintains that its cash method of accounting more clearly reflects the income and expenses of its business. Petitioner argues that respondent may not change its method of accounting from one that clearly reflects income to another method of accounting because the Commissioner determines that the alternate method will reflect petitioner’s income more clearly. Section 446 provides: SEC. 446. GENERAL RULE FOR METHODS OF ACCOUNTING. (a) General Rule.–-Taxable income shall be computed under the method of accounting on the basis of which the taxpayer regularly computes his income in keeping his books. (b) Exceptions.–-If no method of accounting has been regularly used by the taxpayer, or if the method used does not clearly reflect income, the computation of taxable income shall be made under such method as, in the opinion of the Secretary, does clearly reflect income. (c) Permissible Methods.-–Subject to the provisions of subsections (a) and (b), a taxpayer may compute taxable income under any of the following methods of accounting-– (1) the cash receipts and disbursements method; (2) an accrual method; (3) any other method permitted by this chapter; or (4) any combination of the foregoing methods permitted under regulations prescribed by the Secretary.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011