- 25 - The same result obtains if we examine the differences in gross receipts computed under the accrual method and the cash method. For fiscal year 1990 petitioner's gross receipts under the cash method of accounting were $2,115,291. Petitioner's gross receipts under the accrual method of accounting would be $2,465,060. Thus, petitioner's gross receipts under the accrual method increased by $349,769. Petitioner's use of the cash method does not produce results that are substantially identical to the computation of either taxable income or gross receipts under the accrual method. Thus, we hold that respondent did not commit an abuse of discretion in precluding petitioner from continuing to use the cash method of accounting for income tax reporting purposes.9 9 Petitioner, in reliance on Knight-Ridder Newspapers, Inc. v. United States, 743 F.2d 781 (11th Cir. 1984), asserts that it is not required to use the accrual method, because it does not maintain inventory at its warehouse. In Knight-Ridder, the Court of Appeals for the Eleventh Circuit stated that "if either the absolute level of the inventory account or its fluctuation during the year would be substantial, then the taxpayer must use inventories if it meets the other requirements of sec. 1.471-1, [Income Tax Regs]." Id. at 791 In addition to the $701,320 cost of petitioner's material purchases during the year in issue, petitioner maintained a warehouse with materials valued somewhere between $10,000 to $20,000. We find that such inventory is substantial in comparison to petitioner's reported taxable income of $54,128. We note, that petitioner's books and records were insufficient to establish whether there was a substantial fluctuation in its inventory account during the year in issue, however, because we have found that petitioner maintains substantial inventory at its warehouse we need not address the fluctuation issue.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011