Win H. Emert - Page 1

                                 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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