Galedrige Construction, Inc. - Page 6

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                                      OPINION                                        
               The principal issue for decision is whether it was an abuse            
          of respondent's discretion to require petitioner to change from             
          the cash method of accounting to the accrual method of                      
          accounting.3  Subsumed in this issue is the question of whether             
          petitioner should be required to use inventories for tax                    
          purposes.4                                                                  

               3    Sec. 446 provides in pertinent part:                              
                    SEC. 446(a). General Rule.--Taxable income shall be               
               computed under the method of accounting on the basis of                
               which the taxpayer regularly computes his income in keeping            
               his books.                                                             
                    (b) Exceptions.--If no method of accounting has been              
               regularly used by the taxpayer, or if the method used does             
               not clearly reflect income, the computation of taxable                 
               income shall be made under such method as, in the opinion of           
               the Secretary, does clearly reflect income.                            
                    (c) Permissible Methods.--Subject to the provisions of            
               subsections (a) and (b), a taxpayer may compute taxable                
               income under any of the following methods of accounting--              
                    (1) the cash receipts and disbursements method;                   
                    (2) an accrual method;                                            
                    (3) any other method permitted by this chapter; or                
                    (4) any combination of the foregoing methods permitted            
                    under regulations prescribed by the Secretary.                    


               4    Sec. 471 provides in pertinent part:                              
                    SEC. 471(a). General Rule.--Whenever in the                       
               opinion of the Secretary the use of inventories is                     
               necessary in order clearly to determine the income of                  
                                                             (continued...)           




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