Golden Gate Litho - Page 20

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          amounts upon which respondent's adjustments are based.                      
          Further, petitioner's bookkeeper computed the payables by                   
          totaling bills that were due.  The payables did not include                 
          expenses that may have properly accrued under the regulations               
          but for which petitioner had not yet been billed.                           
               Additionally, "No method of accounting will be regarded as             
          clearly reflecting income unless all items of gross profit and              
          deductions are treated with consistency from year to year."                 
          Sec. 1.446-1(c)(2)(ii), Income Tax Regs.  In this case,                     
          respondent did not treat petitioner's accounts payable with                 
          consistency.  The accounts payable of $98,584 at the beginning              
          of the taxable year included all accounts payable ($86,334)                 
          plus all salaries and wages payable ($12,500) reflected on the              
          balance sheet for the taxable year ending May 31, 1990.  The                
          accounts payable of $20,120 for the close of the taxable year               
          included only those payables identified as payables related to              
          the cost of goods sold and did not include $5,111 in accounts               
          payable not related to the cost of goods sold or $11,250 in                 
          salaries and wages payable to Mr. Asher.  Respondent made no                
          adjustments to account for accounts payable at the end of the               
          taxable year related to the $5,111 of operating expenses or                 
          related to the $11,250 of salaries and wages payable.                       
          Respondent's adjustment of these items was improper.  In order              
          to clearly reflect petitioner's income, accounts payable at the             





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