- 36 - 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 aPage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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