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Susan S. Canavello, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Frank's Casing Crew and Rental Tools, Inc.,
petitioned the Court to redetermine respondent's determination of
income tax deficiencies of $182,660, $164,150, and $46,461 in its
taxable years ended August 31, 1989, 1990, and 1991,
respectively. Following concessions by respondent, we must
decide whether respondent committed an abuse of discretion in
changing petitioner's method of accounting for income from
certain of its contracts. We hold for respondent. Unless
otherwise stated, section references are to the Internal Revenue
Code in effect for the years in issue. Rule references are to
the Tax Court Rules of Practice and Procedure. Dollar amounts
are rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations and attached exhibits are incorporated herein by
this reference. Petitioner was incorporated on October 8, 1956,
under the laws of the State of Louisiana. It filed 1988, 1989,
and 1990 Forms 1120, U.S. Corporation Income Tax Return, using an
accrual method and a fiscal year ended August 31.1 It had its
1 Petitioner subsequently amended its 1988 and 1989 tax
returns.
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