- 14 - or regulation will be applied without retroactive effect. That section is not involved here. Petitioner has not provided the names of its competitors who have allegedly obtained the Commissioner’s consent to a change in method of accounting or described the method of accounting to which the Commissioner has supposedly consented. Petitioner’s conclusory allegation of disparate treatment without any showing of specific facts that could possibly bring it with the ambit of the IBM case is insufficient grounds for granting partial summary judgment on the issue before us. To reflect the foregoing, An appropriate order will be issued denying petitioner’s motion for partial summary judgment.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011