- 4 - invoiced until after yearend because of lack of documentation, petitioner followed a similar pattern. Petitioner's use of the invoicing date to control the accrual of income resulted in a deferral of the following amounts of gross receipts for sales and services that were completed during its taxable years ending in 1988, 1989, and 1990 but billed in the respective succeeding taxable years: Taxable year ended Amount Aug. 31, 1988 $846,897 Aug. 31, 1989 553,623 Aug. 31, 1990 927,451 Petitioner accrues various expenses at yearend. OPINION Respondent determined that petitioner's method of accounting erroneously deferred recognizing income from sales and services billed after the year in which they were completed. Respondent argues that this method was inconsistent with the all events test for the accrual of income. Respondent argues that petitioner acquired a fixed right to receive income for these goods and services once it completed performance. Petitioner argues that its right to receive income from these yearend sales and services was not fixed in the year that the goods were delivered or the services rendered, given that it could not invoice its customers until the following year. Petitioner argues that respondent abused her discretion in not accepting its method of accounting, which in petitioner's view results in only "minor deviations"Page: Previous 1 2 3 4 5 6 7 8 Next
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