- 43 - Commissioner, 97 T.C. 120, 128 (1991); UFE, Inc. v. Commissioner, 92 T.C. 1314, 1321 (1989); Sandor v. Commissioner, 62 T.C. 469, 477 (1974), affd. 536 F.2d 874 (9th Cir. 1976). Moreover, an accounting method that conforms to GAAP, but does not comply with the Commissioner's regulations, may not clearly reflect income. Peninsula Steel Prods. & Equip. Co. v. Commissioner, supra. Section 446(c) specifically recognizes as permissible methods of accounting, the cash receipts and disbursements method (cash method), an accrual method, any other method permitted by chapter 1 of the Internal Revenue Code, or any combination of the foregoing methods permitted under regulations prescribed by the Secretary of the Treasury (a hybrid method). Generally, under the cash method of accounting, an item of income or expense is reported when received or paid, without regard to the economic events giving rise to the item. Under an accrual method of accounting, on the other hand, an item of income or expense generally is reported for the accounting period during which all the events have occurred which fix the taxpayer's right to receive the item of income or which establish the fact of liability giving rise to the deduction, and the amount thereof can be determined with reasonable accuracy.18 Hallmark Cards, 18 For years after 1984, sec. 461(h) also requires the occurrence of economic performance with respect to a liability.Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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