Case: Accounting Method Change Impermissible Without Consent, Denial of Related Amortization Deductions Sustained (T.C. Memo) (IRC §446)

In light of a farmland lessor’s (Petitioner) failure to secure accounting method change consent under I.R.C. §446(e), the IRS acted properly in returning Petitioner to its old method and positively adjusting its income for 2013 and 2014 based on denial of amortization deductions claimed for taxable years 2009 through 2012, the U.S. Tax Court held in a memorandum opinion, granting the IRS’s motion for summary judgment and denying Petitioner’s cross-motion. The court denied as moot an IRS motion to strike and ordered the parties to submit a Tax Court Rule 155 computation given that an amended IRS answer ...