Cordes Finance Corporation - Page 19

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                had failed to take into income.  To overcome respondent's                                
                determination as to this accounting adjustment, petitioner                               
                bears a heavy burden of proof in that it must show that                                  
                respondent's determination is arbitrary and unsupported by                               
                any basis in law.  RCA Corp. v. United States, 664 F.2d                                  
                881, 886 (2d Cir. 1981); Prabel v. Commissioner, 91 T.C.                                 
                1101, 1112 (1988), affd. 882 F.2d 820 (3d Cir. 1989).                                    
                      Petitioner's position that respondent's adjustment                                 
                does not comport with the accrual method of accounting                                   
                and is an erroneous method of accounting is based upon                                   
                the premise that the above difference is interest that                                   
                did not accrue in 1990 or in any prior year.  However,                                   
                petitioner has not introduced any evidence to rebut                                      
                respondent's determination or to explain the difference.                                 
                Contrary to the premise of petitioner's argument, the                                    
                ledger cards for loans outstanding at the end of 1990                                    
                substantiate deferred interest of $1,596,968 less than                                   
                the ending balance of the deferred interest account as                                   
                shown on petitioner's balance sheet.  We find that                                       
                petitioner has not proven that respondent abused her                                     
                discretion by determining that the difference described                                  
                above is interest that accrued prior to 1991.  Accordingly,                              
                we hereby sustain respondent's determination.  See Prabel                                
                v. Commissioner, supra.                                                                  
                      Before leaving this issue, we note that petitioner                                 
                made a halfhearted attempt at trial to argue that its                                    



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