Unico Sales & Marketing, Inc. - Page 3




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          (M. Forier) and Richard Forier (R. Forier) were petitioner's                
          officers and directors.   F. Forier and M. Forier (the Foriers)             
          had signature authority over petitioner's bank accounts.                    
               For the subject years, petitioner filed Federal income tax             
          returns purporting to utilize an accrual method of accounting.              
          On these returns, petitioner accrued and deducted unpaid expenses           
          of $286,665 and $199,994 for the respective subject years.  The             
          $286,665 includes $200,000 in unpaid accrued wages to the                   
          Foriers, and the $199,994 includes $18,250 in unpaid accrued                
          wages to the Foriers.   The Foriers did not include these wages             
          in their income until petitioner actually paid them.1  Petitioner           
          had sufficient cash on hand to pay the accrued wages as of the              
          close of each taxable year.                                                 
               Respondent determined and petitioner now agrees that                   
          petitioner should have reported its income under the cash method.           
          Respondent disallowed the deduction of all unpaid accrued                   
          expenses claimed on petitioner's returns.  Petitioner concedes              
          the adjustments in each year except with respect to the unpaid              
          accrued wages to the Foriers.  Petitioner contends that the wages           




               1The Foriers were cash basis, calendar year taxpayers.                 
          Petitioner paid the $200,000 in wages accrued in 1990 in two                
          installments on June 30, 1992, and December 19, 1992, and the               
          Foriers included it in their income for 1992.  Petitioner paid              
          the $18,250 accrued in 1991 on August 2, 1991, and the Foriers              
          included it in their income for 1991.                                       




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