The paper discusses the principles the Supreme Court has developed to decide when the courts should defer to the administrative branch. These principles are then applied to the special case of the Internal Revenue Code’s requirement that an accounting method must clearly reflect income. We conclude that the intent of Congress is that the Commissioner of Internal Revenue should be granted deference in regard to these matters, without regard to the format in which the Commissioner’s position is presented (e.g., regulation, ruling, litigating position). We also demonstrate that the lower Courts often decide clear reflection of income cases as though the court is required to substitute its judgment for that of the administration, which is contrary to the intent of Congress.