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If the Commissioner does not consent to the taxpayer’s
request to make a conforming change in the taxpayer’s
method of computing taxable income, then the taxpayer is
required to continue computing taxable income under the
taxpayer’s old method of accounting. See, e.g., United
States v. Ekberg, 291 F.2d 913, 925 (8th Cir. 1961); Schram
v. United States, 118 F.2d 541, 543-544 (6th Cir. 1941);
Drazen v. Commissioner, 34 T.C. 1070, 1075-1076 (1960)
(and the cases cited thereat); Advertisers Exchange, Inc.
v. Commissioner, supra at 1092-1093.
If the taxpayer changes the method of accounting used
in computing taxable income without first requesting the
Commissioner’s consent, then the Commissioner would appear
to have at least two choices. First, the Commissioner
could assert section 446(e) and require the taxpayer to
abandon the new method of accounting and to report taxable
income using the old method of accounting. See, e.g.,
O. Liquidating Corp. v. Commissioner, supra; Drazen v.
Commissioner, supra at 1076; Advertisers Exchange, Inc.
v. Commissioner, supra at 1093. Second, the Commissioner
could accept the change of accounting method and require
the taxpayer to make any adjustments which might be
necessary to prevent amounts from being duplicated or
omitted, sometimes called transitional adjustments. See
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