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business at hand. Wilkinson-Beane, Inc. v. Commissioner, supra;
Thompson Elec., Inc. v. Commissioner, T.C. Memo. 1995-292;
Honeywell Inc. v. Commissioner, supra; J.P. Sheahan Associates,
Inc. v. Commissioner, T.C. Memo. 1992-239.
Previously, this Court has held that a manufacturer/supplier
of emulsified asphalt and asphalt products that maintained a
yearend inventory of raw materials must use the accrual method of
accounting, even though it had no finished product inventory at
the end of the year. Akers v. Commissioner, T.C. Memo. 1984-208,
affd. on this issue and revd. in part sub nom. Asphalt Prods. Co.
v. Commissioner, 796 F.2d 843, 849 (6th Cir. 1986). In Asphalt
Prods. Co., the taxpayer was in the business of manufacturing
emulsified asphalt from pure asphalt using a chemical treatment
and a physical process. It maintained an inventory of raw
materials and had a fixed production plant with large tanks in
which it was able to preserve the emulsified condition of its
finished product, and therefore its marketable quality,
indefinitely.9 The facts of Asphalt Prods. Co. and the case at
9 Very little road contracting work was done by Asphalt
Products in the colder months of December, January, and February.
Asphalt Products generally closed its operations completely in
mid-December, and all of its employees took vacations from mid-
December until early January. Asphalt Products did not keep any
finished product in its tanks during the 2-week shutdown period.
Akers v. Commissioner, supra.
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