T.C. Memo. 1996-413
UNITED STATES TAX COURT
FRANK'S CASING CREW AND RENTAL TOOLS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 25058-93, 1327-95. Filed September 16, 1996.
P is an "oil field contractor" that sells oil
pipes, leases equipment used in oil fields, and
provides crews necessary to operate the leased
equipment. P's contracts with its customers generally
provide that payment is due when P sends the customer
an invoice that includes all supporting documentation
(i.e., job tickets, equipment tickets, and third party
charges). On a number of occasions during the relevant
years, P did not invoice a customer until after yearend
because it had not yet received a third party's
invoice. In those cases, P did not accrue the related
income until the year during which it invoiced the
customer, even though its contract with the customer
was fully performed by the close of the previous year.
Held: It was not an abuse of discretion for respondent
to conclude that income from the yearend contracts was
accruable for the years in which performance of the
contracts was completed.
Stanley B. Blackstone, for petitioner.
Page: 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011