Hospital Corporation of America and Subsidiaries - Page 60

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          contrary, applied the substantial-identity-of-results test in               
          Asphalt Prods. Co. v. Commissioner, supra.  The taxpayer, which             
          produced and sold emulsified asphalt, had employed the cash                 
          method of accounting from its inception.  Through 1973, the                 
          taxpayer had only nominal inventories on hand at yearend because            
          it normally closed down its operations for several weeks before             
          the end of the year.  The taxpayer's principal customers were               
          county governments in Tennessee that used emulsified asphalt for            
          road construction and maintenance.  The county governments                  
          received revenues required for that purpose from their share of             
          State gasoline taxes.  As an effect of the Arab oil embargo of              
          1973, the price of emulsified asphalt rose rapidly while the                
          consumption of gasoline dropped sharply.  Consequently, the                 
          taxpayer's accounts receivable increased substantially between              
          January 1, 1974, and January 1, 1975.  Additionally, because                
          suppliers of the petroleum residue that was the principal                   
          ingredient of emulsified asphalt required their customers to                
          accept their allocations of the petroleum residue on a monthly              
          basis, the taxpayer had inventories on hand at the end of 1974              
          and 1975.  On audit, the Commissioner determined that the                   
          taxpayer had to use the accrual method of accounting because the            
          use of inventories was necessary to clearly reflect income due to           
          the fact that the production and sale of merchandise was an                 
          income-producing factor.  The Commissioner determined                       
          additionally that the fluctuations in accounts receivable                   




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