Sunoco, Inc. and Subsidiaries - Page 55

                                        - 55 -                                        
             335 (9th Cir. 1962).  As we stated in So. Pac. Transp. Co.               
             v. Commissioner, supra, the Commissioner’s consent is                    
             required when a taxpayer, in a Court proceeding, attempts                
             to alter retroactively the manner in which he accounted                  
             for an item on his tax return.  We reject petitioner’s                   
             argument because of the administrative burden that                       
             would otherwise be placed on the Commissioner.  This                     
             administrative burden is particularly evident in this case               
             where the treatment that petitioner seeks to change had                  
             been followed consistently on its returns from 1983 through              
             1993 until it sold Cordero.                                              
                  On the basis of the above, concessions by the parties,              
             and our prior opinions issued in this case,                              

                                                An appropriate order                  
                                           will be issued.                            




















Page:  Previous  36  37  38  39  40  41  42  43  44  45  46  47  48  49  50  51  52  53  54  55  

Last modified: May 25, 2011