and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: This matter is before the Court
on respondent's Motion for Summary Judgment. Respondent moves
for summary judgment that she did not abuse her discretion in
requiring petitioner to remain on the accrual method of
accounting in computing its income taxes. As explained in
greater detail below, we will grant respondent's motion.
Background2
Milward Corp. is an electrical contracting firm, organized
as a corporation under the laws of the State of Connecticut, with
its principal place of business in Hartford, Connecticut.
Petitioner's business consists primarily of commercial and
industrial work for new construction. George O. Milward
(Milward) is petitioner's president and sole shareholder.
Respondent issued a statutory notice of deficiency to petitioner
determining deficiencies in its Federal corporate income taxes
for the taxable years ending January 31, 1988 through 1990, as
follows:
Taxable Year Ending Deficiency
Jan. 31, 1988 $1,155
Jan. 31, 1989 199,125
2 The following is a summary of the relevant facts that do not appear to
be in dispute. They are stated for purposes of deciding the pending motion.
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