Sunoco, Inc. and Subsidiaries - Page 37

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             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 for                 






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