Carolyn M. Fankhanel - Page 22

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          Respondent’s determination of a deficiency is sustained to the              
          extent it is based on the interest adjustments here described.              
          V.  Real Estate Activities                                                  
               A.  Income                                                             
               Petitioner argues that she is a “cash basis” taxpayer and              
          does not owe taxes on money that was not received.  She states              
          that she managed property for people and, “[i]n order to build              
          a[n] investment program for herself, she took a[n] interest in              
          the property instead of a management fee.”  It is unclear exactly           
          what error petitioner is ascribing to respondent.  Petitioner may           
          misunderstand the term “cash basis”.  The cash receipts and                 
          disbursements method of accounting (cash method) is a permissible           
          method of accounting.  See sec. 446(c)(1).  Generally, under the            
          cash method, all items that constitute gross income, “whether in            
          the form of cash, property, or services” (emphasis added), are              
          includable in gross income for the taxable year in which                    
          received.  Sec. 1.446-1(c)(1)(i), Income Tax Regs.  With certain            
          exceptions not here relevant, “if services are paid for in                  
          property, the fair market value of the property taken in payment            
          must be included in income as compensation”.  Sec. 1.61-2(d)(1),            
          Income Tax Regs.  Petitioner has shown no error in respondent’s             
          adjustments increasing petitioner’s income on account of                    
          compensation received in forms other than cash payments.                    








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