T.C. Memo. 1998-98
UNITED STATES TAX COURT
BUYERS HOME WARRANTY COMPANY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24774-95. Filed March 9, 1998.
William L. Feinstein, for petitioner.
Mark A. Weiner, for respondent.
MEMORANDUM OPINION
RAUM, Judge: The Commissioner determined a $356,179
deficiency in petitioner's 1990 Federal income taxes. The
Commissioner determined that petitioner's method of accounting
did not accurately reflect petitioner's income. The notice of
deficiency changed the method of accounting and implemented a
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