-4- contracted rate. The clients usually pay ASAP within 30 days after they receive the bills. ASAP has no inventory, has never had gross receipts that exceeded $5 million, and has always used the cash method of accounting. Respondent issued petitioners a notice of deficiency on June 3, 1994, reflecting her determination that they were liable for an $85,835 deficiency in their 1990 Federal income tax and a $17,167 penalty under section 6662(a). Prior to issuing the notice of deficiency, respondent's revenue agent, Mr. Willie Wimbish, conducted an examination of ASAP and had several interviews with petitioner and her accountant, Mr. Currie. After the examination, the revenue agent proposed the deficiency in petitioners' 1990 income tax, and prepared a Form 886-A (Explanation of Items) to explain the proposed adjustments. The agent's explanation included the adjustments, along with a statement of facts, law, and petitioners' position and the agent's conclusion as to each item of adjustment. The revenue agent's report provided the legal and factual bases for the issuance of the notice of deficiency. The adjustments in the notice of deficiency were primarily attributable to respondent's determination that ASAP's use of the cash method of accounting did not produce a clear reflection of income (the method of accounting issue). Respondent determined that the proper method of accounting was the accrual method, and using that method respondent increased ASAP's taxable income forPage: 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