Bosamia, et al. v. Commissioner of Internal Revenue, No. 10-60921 (5th Cir. 2011)
Annotate this CaseThis case stemmed from petitioners', the sole shareholders of two Subchapter S corporations, India Music and HRI, engagement in the business of importing and selling music, making those entities related parties under Internal Revenue Code, 26 U.S.C. 267. At issue was whether the Commissioner effected a change in a taxpayer's method of accounting for the purposes of section 481 when he required that taxpayer to postpone a deduction from gross income pursuant to section 267(a)(2). The court held that because it concluded that a section 267(a)(2) disallowance constituted a change in a taxpayer's method of accounting under section 481, the court affirmed the judgment of the Tax Court.
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