Capitol Fed. Sav. & Loan Ass'n v. Commissioner
United States Tax Court
While under examination, petitioner applied, pursuant to Rev. Proc. 80-51, for permission to change a method of accounting and asked for permission to spread the adjustment required under sec. 481(a) over more than 1 year. Respondent refused to consider the application and made the method change and related sec. 481(a) adjustment in the earliest open year under examination.
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While under examination, petitioner applied, pursuant to Rev. Proc. 80-51, for permission to change a method of accounting and asked for permission to spread the adjustment required under sec. 481(a) over more than 1 year. Respondent refused to consider the application and made the method change and related sec. 481(a) adjustment in the earliest open year under examination. Held, respondent properly exercised his discretion under sec. 446(b) in changing petitioner's method of accounting. Held, further, respondent's refusal to consider petitioner's application is reviewable for abuse of…
1Opinion of the Court
WELLS, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax as follows:
FYE Deficiency
Sept. 30, 1978 . $712,766
Sept. 30, 1984. 67,508
After concessions, the issue for decision is whether respondent erred in changing petitioner’s method of accounting for interest income from mortgage passthrough certificates.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and the exhibits attached thereto are incorporated herein by reference. Petitioner is a Federal savings and loan association with its principal place of business in…
2Cases cited89 opinions
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