Cross Oil Company, Inc. - Page 11




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          claims that its receivables, inventory, and payables have                   
          remained consistent from the inception of the business and that             
          it has not attempted to distort its income by unreasonably                  
          prepaying expenses, purchasing supplies in advance, or delaying             
          the receipt of payment from its customers.  Respondent argues               
          that petitioner has failed to demonstrate that there is a                   
          substantial identity of results between the cash method and                 
          accrual method of accounting based on the differences in income             
          between the cash method and accrual method of accounting.                   
               The substantial identity of results test is a judicial                 
          creation that was first articulated in Wilkinson-Beane, Inc. v.             
          Commissioner, supra.  In Wilkinson-Beane, Inc., a cash-method               
          taxpayer who was required to maintain an inventory and, thus,               
          report income on the accrual basis argued that the difference               
          in income that was determined by the method it used and the                 
          method selected by the Commissioner was negligible.  The Court              
          of Appeals held that, where the Commissioner has determined                 
          that the accounting method that is used by a taxpayer does not              
          clearly reflect income, "the taxpayer must demonstrate                      
          substantial identity of results between his method and the                  
          method selected by the Commissioner" in order to prevail.  Id.              
          at 356.  In Ansley-Sheppard-Burgess Co. v. Commissioner, supra              
          at 377, this Court held that a taxpayer that is required to use             
          the inventory method of accounting must meet the substantial                






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