- 5 - Petitioner works on several jobs at a time. Petitioner's contracts generally provide for progress billing on the 25th day of each month. In most cases, petitioner sends its customers a bill once a month until a job is complete. Petitioner's vendors allow 30 days for payment of any materials petitioner orders. Petitioner generally tries to ship any materials ordered for a particular job directly to the job site on or about the 20th day of each month, so that it is not responsible for paying vendor bills until the 20th of the following month. Petitioner had $2,115,291 in gross receipts for the taxable year in issue. Petitioner's material costs2 for the taxable year amounted to 33 percent of its gross receipts. Petitioner's cost of good sold (COGS) was $1,835,723.3 OPINION Issue 1. Whether It Was an Abuse of Respondent's Discretion To Require Petitioner To Change From the Cash Method of Accounting to an Accrual Method of Accounting Respondent determined that the cash receipts and disbursements method of accounting used by petitioner for income tax purposes does not clearly reflect income. Specifically, respondent claims that petitioner must use inventories, and 2 On its tax return for the year in issue, petitioner reported material costs of $701,320. 3 On its tax return for the year in issue, petitioner included the following items in its COGS computation: Material purchases, labor, equipment, subcontractor payments, depreciation, payroll taxes, insurance, operating expenses and other miscellaneous expenditures.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