Sunoco, Inc. and Subsidiaries - Page 36

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             The Consent Requirement                                                  
                  Section 446(e), the provision at issue in this case,                
             provides as follows:                                                     

                       SEC. 446(e).  Requirement Respecting Change                    
                  of Accounting Method.--Except as otherwise                          
                  expressly provided in this chapter, a taxpayer                      
                  who changes the method of accounting on the basis                   
                  of which he regularly computes his income in                        
                  keeping his books shall, before computing his                       
                  taxable income under the new method, secure the                     
                  consent of the Secretary.                                           

                  The purpose of the consent requirement imposed by                   
             section 446(e) is to require consistency in the method of                
             accounting used for tax purposes and, thus, to prevent                   
             distortions of income, which usually accompany a change of               
             accounting methods and which could have an adverse effect                
             upon the revenue.  See Commissioner v. O. Liquidating                    
             Corp., 292 F.2d 225, 231 (3d Cir. 1961), revg. T.C. Memo.                
             1960-29; Wright Contracting Co. v. Commissioner, 36 T.C.                 
             620, 634 (1961), affd. 316 F.2d 249 (5th Cir. 1963); Casey               
             v. Commissioner, 38 T.C. 357, 386-387 (1962); Advertisers                
             Exchange, Inc. v. Commissioner, 25 T.C. 1086, 1092-1093                  
             (1956), affd. per curiam 240 F.2d 958 (2d Cir. 1957).  In                
             part, the consent requirement is also intended to lessen                 
             the Commissioner’s burden of administering the Internal                  
             Revenue Code.  See Lord v. United States, 296 F.2d 333, 335              
             (9th Cir. 1962); Casey v. Commissioner, supra at 386.  In a              





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