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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"
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