- 22 - 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.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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