- 25 - consequence, we conclude EIC did not meet its burden and find that the proper amount of income for 1989 under the accrual method is $19,484,214. Second, respondent contends in the second stipulation of settled issues that EIC is required to report the following income from sales that occurred prior to March 1, 1986: Year Amount of Adjustment 1989 $337,668 1990 418,548 1991 292,745 1992 291,437 EIC contends that it does not have to report any income from sales that occurred prior to March 1, 1986. However, a witness for EIC, Michael Cummins, a C.P.A. who had served as EIC's interim controller, testified on cross-examination that EIC would have to report these amounts if the accrual method were found to be the proper method of accounting. EIC did not address this issue in its opening brief nor its reply brief. Accordingly, we treat this as a concession by EIC and find for respondent. Third, the parties disagreed in the fourth stipulation of settled issues as to the proper amount of income that the Wangs 7(...continued) resolution. Nevertheless, on brief, petitioners do not further address the differences between their calculation of accrual income and the amount determined by respondent.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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