- 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
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