22                                           
               2.   Petitioner's Expert Witnesses                                     
                    a.   Description of the Testimony                                 
               Petitioner called Denton R. Hammond (Hammond) and Gross as             
          expert witnesses.  Respondent called no expert witnesses.                   
               Hammond and Gross are certified public accountants.  Hammond           
          specializes in construction industry accounting.  Gross prepared            
          Eagle’s tax returns for the years at issue in this case and                 
          conducted the study relating to Eagle’s deposits.                           
               Hammond and Gross concluded that:  (i) Eagle accounted for             
          payments it received from customers for panelized house kits                
          consistently for both financial and tax purposes, (ii) the method           
          of accounting Eagle used for tax purposes conformed to its books            
          and records and its issued financial statements, (iii) Eagle's              
          method of accounting properly matches income and expenses for               
          financial accounting purposes, and (iv) Eagle's method of                   
          accounting complies with GAAP.                                              
               Hammond also concluded that Eagle's method of accounting               
          clearly reflects its income for the years in issue, is as                   
          accurate in reporting the results of operations as accounting               
          systems allow, and complies with GAAP as provided in the AICPA’s            
          Statement of Position 81-1, “Accounting for Performance of                  
          Construction-Type and Certain Production-Type Contracts”.  He               
          also concluded that respondent's method mismatches items of                 
          revenue and expense under GAAP.                                             
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