Anderson Columbia Co. v. United States

OPINION

MEROW, Judge.

This tax case concerns plaintiffs claim for a refund of interest paid. This matter is before the Court on cross-motions for summary judgment. As a result of plaintiffs change in its method of accounting, plaintiff was required to adjust its taxable income upward on a past return and interest was assessed on the difference in tax owed. Plaintiff contends that interest is inappropriate because the consent of the Commissioner of Internal Revenue was required before it could change its method of accounting. Therefore, plaintiff argues, the resulting increase in tax liability…