Frank's Casing Crew and Rental Tools, Inc. - Page 2

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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                

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