RACMP Enterprises, Inc. - Page 49




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          accepted by the developer/customer and, accordingly, for which              
          income was not reported).  All of those items may have had a                
          significant effect on petitioner’s reportable taxable income.               
          Again, petitioner has not shown the amount of materials on hand             
          or work in progress as of the end of the taxable year under                 
          consideration.2                                                             
               Petitioner, at the end of its very first year in existence,            
          had accounts receivable of $294,436 on accrual method gross                 
          receipts of $1,798,338; i.e., 16.4 percent of its receipts were             
          unreported at the end of its taxable year.  Moreover, the                   
          accounts receivable of $294,436 was 18.8 percent of the reported            
          gross receipts, under the cash method, of $1,564,045.  If the               
          taxable income reported by petitioner included the receivables              
          under the accrual method of income, petitioner would have                   
          reported taxable income of $267,428.  Petitioner claimed cost of            
          goods sold in the amount of $993,777, which resulted in taxable             
          income on the cash method of $64,806.  Any reduction in cost of             
          goods sold, of course, would increase income.  In spite of these            


               2 The existence of $294,436 in accounts receivable at the              
          end of petitioner’s very first taxable year may indicate that               
          petitioner had a substantial amount of completed work and work in           
          progress for which it had not been paid, but for which it had               
          deducted the cost of materials.  Under the cash method, the                 
          accounts receivable and work in progress for which payment has              
          not been received are not included in gross receipts.  A mismatch           
          thus occurs by the overstatement of deductions for materials                
          under the cash method.  In this case, the mismatch is potentially           
          large considering that the accounts receivable represent a large            
          percentage of the gross receipts for the tax year under                     
          consideration.                                                              



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