- 14 - year accordingly. However, petitioners have not shown that B&W was reimbursed in an amount greater than that conceded by respondent for fiscal year 1996. Petitioners contend that respondent’s disallowance of B&W’s deduction of those costs would have the effect of improperly putting B&W on the accrual method of accounting. We disagree. Although cash-basis taxpayers may deduct business expenses in the taxable year paid, the costs advanced by B&W for its clients were in the nature of reimbursable loans and were not deductible. Respondent’s disallowance of those deductions did not put B&W on the accrual method of accounting. Petitioners claim that they may deduct as business expenses amounts advanced on behalf of clients just as farmers may deduct their expenses for fertilizers, chemicals, and fuel. We disagree. Tax rules for farmers do not make B&W’s payment of client costs deductible. Petitioners contend that respondent permitted B&W to deduct as business expenses advances for client costs in prior years, and claim that its identical treatment of client costs during the years in issue must similarly be accepted. We disagree. First, petitioners offered no evidence of a prior examination or audit of B&W’s tax returns and thus have not shown that respondent allowed B&W to deduct client advances in prior years. Second, respondent is not precluded from raising an issue even ifPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011