- 60 -
answer may not have been intended. Taxpayers similarly situated
to petitioner should be prepared to demonstrate that the cash
method clearly reflects their income or that the hybrid method
does not.8
V. Conclusion
For the foregoing reasons, I dissent from the majority’s
opinion.
COHEN, WHALEN, and CHIECHI, JJ., agree with this dissent.
8 Taxpayers may have difficulty in proving that a method of
accounting such as the hybrid method does not clearly reflect
income. In Hospital Corp. of Am. v. Commissioner, T.C. Memo.
1996-105, we concluded that certain hospitals’ use of a hybrid
method of accounting that reported on an accrual method revenue
allocable to charges for supplies and pharmaceuticals clearly
reflected the hospitals’ income
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