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
Capitol Federal Savings & Loan Association & Subsidiary, Petitioner v. Commissioner of Internal Revenue, Respondent
Capitol Fed. Sav. & Loan Ass'n v. Commissioner
Docket No. 20681-88
United States Tax Court
96 T.C. 204; 1991 U.S. Tax Ct. LEXIS 11; 96 T.C. No. 11;
February 13, 1991, Filed
Decision will be entered for the respondent.
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…
2Cases cited91 opinions
- United States Ex Rel. Accardi v. ShaughnessySupreme Court of the United States · 1954
- Chrysler Corp. v. BrownSupreme Court of the United States · 1979
- United States v. CaceresSupreme Court of the United States · 1979
- Service v. DullesSupreme Court of the United States · 1957
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
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