- 13 - Inc. v. Commissioner, T.C. Memo. 1992-239; Akers v. Commissioner, T.C. Memo. 1984-208, affd. on this issue sub nom. Asphalt Prods. Co. v. Commissioner, 796 F.2d 843 (6th Cir. 1986), revd. on another issue 482 U.S. 117 (1987). We find that petitioner's sale of merchandise is an income-producing factor and, therefore, petitioner is required to maintain inventories. B. Whether It Was an Abuse of Respondent's Discretion To Change Petitioner From the Cash Method to Respondent's Method of Accounting The regulations provide that, unless otherwise authorized by the Commissioner, a taxpayer who is required to account for inventories must use the accrual method of accounting with regard to purchases and sales. Sec. 1.446-1(c)(2)(i), Income Tax Regs. Respondent argues that petitioner must account for inventories and must use the accrual method of accounting. In this case, however, the facts show that respondent completely disregarded the applicable provisions of the Internal Revenue Code and regulations and made no attempt to properly value petitioner's inventory or compute petitioner's income using a proper accrual method of accounting. 1. Respondent's Method of Valuing Petitioner's Inventory Was Improper Rules governing the valuation of inventories are set forth in regulations promulgated under section 471 and the uniformPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011