supports their argument that the two provisions “are not to be read together.” They submit that the requirements of § 481 are mandatory, providing that the Commissioner “shall” make “necessary” adjustments to a taxpayer’s income to avoid the “omission” of income from tax. Thus, the Taxpayers maintain that we would expect to find precedent for the proposition that a § 267(a)(2) disallowance constitutes a change in a taxpayer’s accounting method necessitating a § 481 adjustment if that has been the Commissioner’s consistent position. In essence, the Taxpayers’ argument amounts to a claim that the Commissioner has changed his interpretation of the Code and relevant Treasury Regulations with retroactive effect. See Microcomputer Tech. Inst. v. Riley, 139 F.3d 1044, 1050 (5th Cir.1998) (<HOLDING>). But our review does not reveal any case where
holding that when an agency changes its policy with retroactive effect a reviewing court must determine the reasonableness of the new interpretation and whether application of the new policy to a party who relied on the old is so unfair as to be arbitrary and capricious holding that in reviewing a claim construction decided under the broadest reasonable interpretation standard we determine whether the interpretation is within the range of reasonableness holding that plan language granting the plan administrator the sole discretion to construe the terms of a long term disability policy and to determine eligibility under the policy triggered arbitrary and capricious review holding that under the arbitrary and capricious standard this court must consider whether the decision was based on a consideration of the relevant factors and whether there has been a clear error of judgment holding that when applying an arbitrary and capricious standard of review the courts role is to determine whether the plan administrators decision was completely unreasonable