- 37 - recent case, this Court identified the following as the policy reasons served by section 446(e): (1) To protect against the loss of revenues; (2) to prevent administrative burdens and inconvenience in administering the tax laws; and (3) to promote consistent accounting practice thereby securing uniformity in collection of the revenue. FPL Group, Inc. & Subs. v. Commissioner, 115 T.C. at 574 (quoting Barber v. Commissioner, 64 T.C. 314, 319 (1975)). Section 446(e) in Operation By requiring the taxpayer to obtain the Commissioner’s consent before changing his method of accounting, section 446(e) gives the Commissioner authority to approve or disapprove such conforming changes prospectively. We have held that a logical inference to be drawn from section 446(e) is that the Commissioner also has authority to consent to a change in a taxpayer’s method of computing taxable income that has already been made; i.e., to give consent retroactively. See Barber v. Commissioner, 64 T.C. 314, 319 (1975). Generally, in order to secure the Commissioner’s consent to a change of a taxpayer’s method of accounting before 1998, the taxpayer was required to file an application with the Commissioner on a form provided forPage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
Last modified: May 25, 2011