- 16 - deferred interest of $1,596,968 more than the amount recorded on petitioner's loan ledger cards. In order to reconcile this discrepancy, and to bring the balance of petitioner's deferred interest account in line with the ending balance computed by respondent from petitioner's loan ledger cards, viz $3,091,395.88, respondent increased petitioner's income in the amount of $1,596,968. The effect of both elements of respondent's adjustment on petitioner's deferred interest account can be summarized as follows: Deferred interest--ending balance per tax return $7,772,543.00 Less: Earned interest per respondent 3,084,179.12 Less: Amount to reconcile discrepancy in deferred interest amount 1,596,968.00 Deferred interest--ending balance per loan ledger cards 3,091,395.88 Petitioner objects to the second element of respondent's adjustment. Petitioner's position is that this element has the effect of requiring petitioner to include in its income for 1990 interest that would otherwise not accrue until after 1990. Petitioner's post-trial brief states as follows: The Commissioner's proposed method of accounting requires that any interest which has not already been recognized and which could possibly be earned at any time in the future on any contractPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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