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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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