-17-
1(c)(1)(ii), 1.451-1(a), Income Tax Regs. Thus, each method
properly applied to the same facts, may yield different results.
This Court is aware that "By definition, the cash method may
result in mismatching between expenses and income where expenses
are paid in a year prior to the receipt of the related income."
RLC Indus. Co. v. Commissioner, 98 T.C. 457, 493 n.29 (1992),
affd. 58 F.3d 413 (9th Cir. 1995). However, mismatches between
expenses and income will over time tend to cancel out provided no
attempt is made to unreasonably prepay expenses or purchase
supplies in advance. Van Raden v. Commissioner, 71 T.C. 1083,
1104 (1979), affd. 650 F.2d 1046 (9th Cir. 1981). Respondent did
not contend that petitioner attempted to unreasonably prepay
expenses or purchase supplies in advance. Therefore, the fact
that expenses and income are mismatched due to ASAP's use of the
cash method of accounting, by itself, does not provide support
for respondent's determination that the use of the cash method of
accounting does not clearly reflect income.
Furthermore, respondent's determination that ASAP's use of
the accrual method of accounting would increase its 1990 taxable
income by $246,536 is not, per se, indicative that ASAP's use of
the cash method failed to clearly reflect income. RLC Indus. Co.
v. Commissioner, supra at 503. The best method is not
necessarily the one that produces the most tax in a particular
year. Id.
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