T.C. Memo. 1996-413 UNITED STATES TAX COURT FRANK'S CASING CREW AND RENTAL TOOLS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 25058-93, 1327-95. Filed September 16, 1996. P is an "oil field contractor" that sells oil pipes, leases equipment used in oil fields, and provides crews necessary to operate the leased equipment. P's contracts with its customers generally provide that payment is due when P sends the customer an invoice that includes all supporting documentation (i.e., job tickets, equipment tickets, and third party charges). On a number of occasions during the relevant years, P did not invoice a customer until after yearend because it had not yet received a third party's invoice. In those cases, P did not accrue the related income until the year during which it invoiced the customer, even though its contract with the customer was fully performed by the close of the previous year. Held: It was not an abuse of discretion for respondent to conclude that income from the yearend contracts was accruable for the years in which performance of the contracts was completed. Stanley B. Blackstone, for petitioner.Page: 1 2 3 4 5 6 7 8 Next
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