- 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.
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