- 2 - 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.Page: 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