- 6 -
apply to petitioner for the taxable years at issue. In addition,
we find that petitioner's method of accounting clearly reflects
income, and that it was an abuse of respondent's discretion to
require petitioner to use the accrual method of accounting.3 See
Galedrige Constr., Inc. v. Commissioner, supra.
For the foregoing reasons,
Decision will be entered
under Rule 155.
3 Respondent acknowledges that the facts of the instant
case and Galedrige Constr., Inc. v. Commissioner, T.C. Memo.
1997-240, are similar. Notwithstanding this acknowledgment,
respondent attempts to distinguish Galedrige Constr., Inc. from
the instant case. We find these distinctions unconvincing.
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Last modified: May 25, 2011