Oakcross Vineyards, LTD., Dennis D. Groth, Tax Matters Partner - Page 33

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          for Vineyards' generous payment terms to Winery and that no                 
          material distortion of Vineyards' income occurred.                          
               We further conclude that petitioner has failed to establish            
          that respondent’s determination that use of the cash method to              
          report Vineyards' income from sales of grapes and other property            
          did not clearly reflect Vineyards' income and that use of the               
          accrual method was required in order to clearly reflect its                 
          income was an abuse of respondent’s discretion.                             
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          



























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