Galedrige Construction, Inc. - Page 2

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               John P. McDonnell, for petitioner.                                     
               Ronald G. Dong, for respondent.                                        


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               PARR, Judge:  Respondent determined deficiencies in                    
          petitioner's Federal income tax for taxable years 1989 and 1990             
          of $111,613 and $775, respectively.  Respondent also determined a           
          section 6661 addition to petitioner's tax of $27,903 for taxable            
          year 1989.  All section references are to the Internal Revenue              
          Code in effect for the taxable years in issue, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure,            
          unless otherwise indicated.  All dollar amounts are rounded to              
          the nearest dollar.                                                         
               The issue for decision is:  Whether respondent's                       
          determination that petitioner must account for inventories and              
          use the accrual method of accounting (accrual method) was an                
          abuse of discretion where petitioner accounted for the materials            
          consumed in its service business as supplies.  We hold it was.1             
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated.  The stipulated                
          facts and the accompanying exhibits are incorporated into our               

               1    Due to our finding that petitioner is not required to             
          use an inventory method of accounting, and that respondent abused           
          her discretion in requiring petitioner to change its method of              
          accounting, we need not address the issue of whether petitioner             
          is liable for an addition to tax or penalty for a substantial               
          understatement of income tax.                                               




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