Highland Farms, Inc. and Subsidiary - Page 19

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          cluster homes.                                                              
               Respondent audited petitioner's Federal income tax returns             
          for the taxable years 1974 and 1975.  Respondent made no changes            
          to petitioner's method of accounting as a result of that audit.             
               Petitioner filed its Federal corporate income tax return               
          (Form 1120) for the taxable year 1988, based on the calendar                
          year, using the accrual method of accounting.  Since late 1985,             
          accountant David Worley (Worley) has prepared petitioner's                  
          returns and financial statements; the accounting firm of                    
          Deloitte, Haskins and Sells (DHS) had prepared those returns and            
          financial statements completed prior to that time.  Worley's firm           
          reviewed the previous work of DHS, agreed with their preparation,           
          and followed the same method.                                               
               In reviewing petitioner's Federal income tax return for the            
          taxable year 1988, respondent determined that petitioner's method           
          of accounting for the entry fees did not clearly reflect income             
          in that the entire amount of the entry fees should have been                
          reported in the year of receipt.  Respondent adjusted                       
          petitioner's income to include $1,645,020 of unreported entry               
          fees received through December 31, 1987, plus $115,387 of                   
          unreported entry fees received for taxable year 1988, for a total           
          adjustment of $1,760,407 related to the entry fees.                         
               Respondent also determined that petitioner's method of                 
          accounting for the cluster home transactions did not clearly                
          reflect income in that those transactions should have been                  
          accounted for as sales.  Respondent increased petitioner's                  
          cluster home income by $5,001,633 based on petitioner's stated              



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