- 2 - 9817-96 12/31/92 233,413 46,683 12/31/93 111,093 22,219 All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions,1 the issues for decision are (1) whether respondent determined that the method of accounting used by Addison Engineering, Inc. (AEI), did not clearly reflect income, and (2) whether AEI must change from the cash method to the accrual method of accounting for its tax years ending on October 31, 1992 and 1993.2 FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of facts, the stipulation of settled issues, and the attached exhibits are incorporated herein by this reference. At the time petitioners filed their petitions, AEI and Addison Distribution, Inc. (Distribution), each had their principal places of business in San Jose, California, and Win H. Emert (Mr. Emert) resided in San Carlos, California. 1 Respondent concedes that petitioners are not liable for the accuracy-related penalties. 2 The parties filed a stipulation of settled issues which resolved all other issues. Our decision regarding these issues affects the flowthrough tax consequences to petitioner Win H. Emert, AEI's sole shareholder.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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