Ronald D. and Paula J. Pittman, et al. - Page 4




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          days, and all jobs are completed within 5 days.  Completed orders           
          are immediately shipped to the customer.                                    
               IC maintains both its income tax and its financial                     
          accounting records on the cash/hybrid method of accounting and              
          has used that method since its incorporation.  The cash/hybrid              
          method of accounting is the standard method of accounting for               
          this type and size of company.  IC has not attempted to prepay              
          expenses or defer the recognition of income.                                
               IC timely filed its 1994 income tax return.  On that return,           
          IC reported gross receipts of $1,176,035 and claimed cost of                
          goods sold of $822,946, of which $525,861 (or 44.7 percent of               
          gross receipts) consisted of purchases.                                     
          Respondent determined that IC should be required to use the                 
          accrual method of accounting because its cash/hybrid method did             
          not clearly reflect its income.  Respondent's determination                 
          served to increase IC's ordinary income.  Thereafter, respondent            
          issued separate notices of deficiency, each dated November 7,               
          1997, to petitioners determining deficiencies in petitioners'               
          Federal income taxes for 1994 in the following amounts:                     
                              Docket No.     Deficiency                               
                              2396-98        $6,019                                   
                              2397-98        3,611                                    
                              2464-98        5,070                                    
               By separate petitions, each filed on February 9, 1998,                 
          petitioners commenced their cases in this Court.  Respondent                







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