- 51 - implicitly agreed that the income from crypt sales was taxable in the year the mausoleum was completed, regardless of when the cash had been collected. Generally, when property is exchanged for cash, the receipt of cash clearly reflects the receipt of income from the sale of the property. However, when cash is received in exchange for a promise to transfer property that is not yet constructed, the amount or existence of income is less clear. As to the crypt sales in issue, a pure cash receipts and disbursements method of accounting would recognize income from the sale of a crypt when cash is received but would delay deduction of the cost of construction until the cash is spent, certainly not a clear reflection of income. See Rotolo v. Commissioner, 88 T.C. 1500, 1514 (1987) ("'the cost of goods sold must be deducted from gross receipts in order to arrive at gross income'" (quoting Sullenger v. Commissioner, 11 T.C. 1076, 1077 (1948))); see also Veenstra & DeHaan Coal Co. v. Commissioner, 11 T.C. 964 (1948). Until a mausoleum was completed, Woodbine's overall method of accounting would not clearly reflect income from crypt sales. Either the costs of construction would have to be estimated and accrued, and a portion expensed, or the recognition of gross receipts delayed until receipts could be matched with the costs of construction. Neither method would appear to reflect income more clearly than the other. Without a showing either that Woodbine's overall method of accounting would clearly reflect income from mausoleumPage: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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