- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
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