-168-
1994), affg. 95 T.C. 415 (1990); Booth v. Commissioner, 108 T.C.
524, 569 (1997). We understand from the legislative history that
Congress intended that the mark-to-market rules under section
475, including the valuation requirement subsumed therein, be
considered a method of accounting. In fact, the House Committee
on Ways and Means even articulated in its report a specific
provision as to the procedure to be used by taxpayers who were
required to change their methods of accounting to comply with the
legislation. H. Rept. 103-111, at 666 (1993), 1993-3 C.B. 167,
242. This provision refers to “A taxpayer that is required to
change its method of accounting to comply with the requirements
of the provision”, a “section 481(a) adjustment”, and the need to
account for the section 481 adjustment through the “principles of
* * * Rev. Proc. 92-20", 1992-1 C.B. 685, the revenue procedure
that governs the changes in method of accounting in general.
These references, we believe, are most consistent with our
conclusion that the applicable mark-to-market rule is a method of
accounting.
We also bear in mind Congress’s placement of section 475 in
part II of subchapter E (chapter 1) of the Internal Revenue Code,
a part that is entitled “Methods of Accounting”. This placement,
of course, is by no means dispositive. Sec. 7806(b). This
placement, however, can surely not be ignored. Sec. State Bank
v. Commissioner, 214 F.3d 1254, 1257-1258 (10th Cir. 2000), affg.
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