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          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 accrual             
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