- 15 - Year Amount 1990 $1,440,821 1989 923,274 1988 488,357 1987 179,881 1986 43,181 1985 8,470 1984 195 3,084,179 Petitioner's trial memorandum makes the following statement concerning this element of respondent's adjustment: Respondent's schedule indicates it totals $3,084,179, but it actually foots to $3,079,767. Aside from this small difference, petitioner agrees that if a change in accounting method is required here, this is the correct method to use and that it arrives at the correct starting point to compute 1990 income. Petitioner did not specifically take issue with this element of respondent's adjustment, either at trial or in its post-trial briefs. The second element of respondent's adjustment is based upon the discrepancy in petitioner's deferred interest account. On the one hand, the balance sheet submitted with petitioner's 1990 return as Schedule L reports $7,772,543 as the balance of petitioner's deferred interest account at the end of 1990. On the other hand, the aggregate deferred interest recorded on the ledger cards for all of the loans outstanding at the end of 1990 is $6,175,575. Thus, petitioner's balance sheet reportsPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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