Cross Oil Company, Inc. - Page 2




                                        - 2 -                                         
          it was an abuse of respondent’s discretion, under section 446, to           
          require petitioner to change from the cash method of accounting             
          to the accrual method of accounting in order to reflect clearly             
          the income of petitioner’s oil and gas business.                            
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
               Petitioner Cross Oil Company, Inc., is an Oklahoma                     
          corporation with its principal place of business in Ponca City,             
          Oklahoma.  Petitioner is engaged in the wholesale and retail sale           
          of gasoline, diesel fuel, oil, and other petroleum products.                
               Petitioner sells and distributes a premanufactured product             
          to its customers.  Petitioner’s sales are mostly in bulk form, in           
          which large orders of petroleum products are loaded at the local            
          refinery and delivered directly to the customer by petitioner or            
          by a contract truck hired by petitioner.  Petitioner also                   
          maintains an inventory, of generally not more than a 2-1/2 week             
          supply of products, at its business location.  The inventory that           
          is available for sale at petitioner’s place of business is either           
          delivered to or picked up by the customers.  Petitioner’s                   
          purchases of petroleum products are made as a 10-day net sale               




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011