- 40 -
Ryan v. Commissioner, 42 T.C. 386, 391 (1964); Patchen
v. Commissioner, 27 T.C. at 597-598; cf. Brookshire v.
Commissioner, 31 T.C. 1157, 1162-1164 (1959), affd. 273
F.2d 638 (4th Cir. 1960); Carver v. Commissioner, 10 T.C.
171, 174 (1948), affd. per curiam 173 F.2d 29 (6th Cir.
1949); Yates v. United States, 205 F. Supp. 738, 740-741
(E.D. Ky. 1962). Since the enactment of section 481, a
taxpayer has been required to make such adjustments if the
taxpayer’s taxable income is computed using a method of
accounting different from the method under which the
taxpayer’s income for the preceding taxable year was
computed. See sec. 481(a).
In deciding whether to consent to a change of
accounting method, the Commissioner is invested with wide
discretion. See, e.g., Commissioner v. O. Liquidating
Corp., 292 F.2d at 231; Capital Fed. Sav. & Loan
Association & Subs. v. Commissioner, supra at 213; Drazen
v. Commissioner, supra at 1076. In a case in which the
taxpayer has requested the Commissioner’s consent to change
methods of accounting, the Commissioner’s action in
refusing to give consent is reviewed under an abuse of
discretion standard. See Brown v. Helvering, 291 U.S. at
204; Schram v. United States, supra at 544; Capital Fed.
Sav. & Loan Association & Sub. v. Commissioner, supra at
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