T.C. Memo. 1999-175
UNITED STATES TAX COURT
WIN H. EMERT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 9817-96. Filed May 24, 1999.
David M. Kirsch, for petitioner.
Steven Walker, for respondent.
SUPPLEMENTAL MEMORANDUM OPINION
VASQUEZ, Judge: The controversy before us arises out of
* On August 6, 1998, the Court issued its opinion on the
merits (T.C. Memo. 1998-289), which we incorporate herein. We
sustained respondent's determination that (1) the method of
accounting used by petitioner's wholly owned S corporation (AEI)
did not clearly reflect income, and (2) AEI must change its
method of accounting from the cash method to the accrual method
for its tax years ending on October 31, 1992 and 1993. The Court
directed that "Decisions will be entered under Rule 155." Our
prior opinion regarded two consolidated cases. Only the
computation for docket No. 9817-96 is at issue herein.
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