- 2 - partnership’s self-employment income by the same amount. Unless otherwise noted, all section references are to the Internal Revenue Code (Code) in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issue to be decided is whether respondent's determination that Vineyards must report its income from the sale of grapes and other property on the accrual method, rather than the cash receipts and disbursements method, in order to clearly reflect its income was an abuse of respondent’s discretion. FINDINGS OF FACT Some of the facts have been stipulated for trial pursuant to Rule 91. The parties’ stipulations of fact are incorporated herein by reference and are found as facts in the instant case. At the time the petition in the instant case was filed, Vineyards maintained its principal place of business in Oakville, California. General Background Vineyards Vineyards was organized on May 26, 1981, as a California limited partnership to acquire and operate a vineyard in California's Napa Valley. Mr. Groth and his wife Judith (sometimes referred to herein together as the Groths) are the general partners of Vineyards and own an 85-percent interest in the partnership. Trusts for the benefit of each of the Groths'Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011