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this purpose, Form 3115, during the taxable year in which
it was deemed to have made the change. Sec. 1.446-
1(e)(3)(i), Income Tax Regs. In effect, the filing of
such an application for consent to a change in accounting
method is a request for a ruling from the Commissioner.
See Capital Fed. Sav. & Loan Association & Subs. v.
Commissioner, 96 T.C. at 211; sec. 601.204(c), Statement
of Procedural Rules. The issuance of such a ruling is a
matter within the discretion of the Commissioner. Capital
Fed. Sav. & Loan Association & Subs. v. Commissioner, supra
at 212.
The Commissioner will not grant permission to change
a taxpayer’s method of accounting unless the taxpayer and
the Commissioner agree to the prescribed terms, conditions,
and adjustments under which the change will be effected,
including the taxable year or years in which any adjustment
necessary to prevent amounts from being duplicated or
omitted is to be taken into account. See sec. 1.446-
1(e)(3)(i), Income Tax Regs. The general terms and
conditions under which the Commissioner will consent to a
change of accounting method are set forth from time to time
in revenue procedures. The revenue procedures applicable
to the years in issue are Rev. Proc. 80-51, 1980-2 C.B.
818, superseded by Rev. Proc. 84-74, 1984-2 C.B. 736.
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