- 21 - beginning and the end of the year should have been treated in a consistent manner. If the accounts payable were to be allocated between those related to the cost of goods sold and those related to operating costs, an allocation should also have been made for accounts payable at the beginning of the taxable year. Then proper adjustments could be made to the cost of goods sold and to the deduction for operating expenses. Additionally, since respondent treated all accounts payable at the beginning of the year as related to the cost of goods sold, there would have been no accounts payable at the beginning of the year related to operating expenses. Therefore, respondent should have increased petitioner's deduction for operating expenses (reducing petitioner's income) by $16,361 to reflect the increase in payables related to operating expenses at the close of the year. We find respondent's determinations with respect to petitioner's accounts receivable and payable to be unreasonable, arbitrary, and without basis in law. 3. It Was an Abuse of Respondent's Discretion To Change Petitioner From the Cash Method to Respondent's Improper Method of Accounting During the 12-month examination of petitioner's records, the agent made no attempt to properly value petitioner's inventories or value payables and receivables under the accrualPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011