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Co. v. Commissioner, 104 T.C. at 375; sec. 1.446-1(a)(2), Income
Tax Regs.; sec. 1.466-1(c)(1)(ii)(C), Income Tax Regs.
According to petitioner’s expert report and audited
financial statements, petitioner’s method is “in all material
respects * * * in conformity with generally accepted accounting
principles.” See sec. 1.466-1(c)(1)(ii)(C), Income Tax Regs.;
see also Van Raden v. Commissioner, 71 T.C. 1083, 1104-1105
(1979), affd. 650 F.2d 1046 (9th Cir. 1981); sec. 1.446-1(a)(2),
Income Tax Regs. Also according to petitioner’s industry
experts, petitioner’s method is in accordance with the accepted
practices in its trade or business. See sec. 1.446-1(a)(2),
Income Tax Regs.; see also Molsen v. Commissioner, 85 T.C. 485,
506 (1985); Madison Gas & Elec. Co. v. Commissioner, 72 T.C. 521,
556 (1979), affd. 633 F.2d 512 (7th Cir. 1980); Auburn Packing
Co. v. Commissioner, 60 T.C. 794, 799 (1973); Sam W. Emerson Co.
v. Commissioner, 37 T.C. 1063, 1068 (1962).
The Commissioner cannot require a taxpayer to change from an
accounting method that clearly reflects income to an alternate
method of accounting merely because the Commissioner considers
the alternate method to reflect income more clearly. Ansley-
Sheppard-Burgess v. Commissioner, supra at 371; Molsen v.
Commissioner, supra at 498; Peninsula Steel Prods. & Equip. Co.
v. Commissioner, 78 T.C. at 1045; Bay State Gas Co. v.
Commissioner, 75 T.C. at 422. Respondent’s proposed change to
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