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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.
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Last modified: May 25, 2011