Mid Del Therapeutic Center, Inc. - Page 22

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                  In light of our holding, we find it unnecessary to address                           
            petitioners' additional assignments of error.8  We have carefully                          
            considered all remaining arguments made by respondent for a                                
            result contrary to that expressed herein, and to the extent not                            
            discussed above, we find them to be irrelevant or without merit.                           
                  To reflect the foregoing,                                                            

                                                            Decisions will be entered                  
                                                      for petitioners.                                 

                  8On brief, petitioners made several additional arguments in                          
            support of their contention that respondent abused his                                     
            discretion.  Petitioners argued that the cash method clearly                               
            reflected their income, irrespective of whether inventories were                           
            required by sec. 1.471-1, Income Tax Regs.; that an audit of Mid-                          
            Del’s 1993 Form 1120 resulted in an authorization for Mid-Del                              
            (and PC, by implication) to use the cash method; that sec. 448                             
            permitted petitioners' continued use of the cash method, also                              
            irrespective of whether merchandise inventories were required;                             
            and finally, that computational errors were made in the sec. 481                           

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