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We disagree with petitioner that respondent’s determination
is an abuse of discretion. Section 446(a) contains the general
rule for tax accounting. Section 446(a) provides that the
accounting method used to compute taxable income generally must
be based on the method of accounting used to compute book income.
When the accounting method used to compute taxable income does
not clearly reflect income, section 446(b) gives the Commissioner
broad authority to prescribe a method that does clearly reflect
income. Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 532
(1979); Commissioner v. Hansen, 360 U.S. 446, 467 (1959); see
also sec. 1.446-1(a)(2), Income Tax Regs. (“no method of
accounting is acceptable unless, in the opinion of the
Commissioner, it clearly reflects income”). The Commissioner’s
exercise of authority under section 446(b) is given “much
latitude” and cannot be disturbed unless “clearly unlawful”.
Thor Power Tool Co. v. Commissioner, supra at 532-533; Lucas v.
Am. Code Co., 280 U.S. 445, 449 (1930); see also United States v.
Catto, 384 U.S. 102 (1966); Schlude v. Commissioner, 372 U.S.
128, 133-134 (1963); Am. Auto. Association v. United States, 367
U.S. 687, 697-698 (1961); Auto. Club of Mich. v. Commissioner,
353 U.S. 180, 189-190 (1957); Brown v. Commissioner, 291 U.S.
193, 203 (1934). Taxpayers challenging the Commissioner’s
authority must prove that the Commissioner’s determination is
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