Acar v. Comm'r., 545 F.3d 727 (9th Cir. 2008)

(plaintiff not entitled to refund for 1999 tax year on basis of purported retroactive election of the mark-to-market method of accounting under I.R.C. §475(f) because election was untimely under Rev. Proc. 99-17 and petitioner was not entitled to an extension of time).