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March 27, 2023

Company leasing farmland impermissibly changed accounting methods, Tax Court holds

In Conmac Investments Inc. v. Commissioner, the Tax Court has held a corporation's new accounting method was impermissible because the company had failed to obtain consent to change accounting methods, as required under IRC Section 446(e). Sustaining the Service's IRC Section 481 adjustment, upon returning the petitioner to its original accounting method, the court rejected the petitioner's assertion that "a change in underlying facts" required the new method.

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor