- 13 - determination that Smith Floors is required to use the accrual method of accounting was an abuse of discretion. We recognize that the cash method of accounting may result in mismatching for income tax purposes when an expense is incurred in one taxable period and the related income is not realized until a later period. See RLC Indus. Co. v. Commissioner, 98 T.C. 457, 493 (1992), affd. 58 F.3d 413 (9th Cir. 1995). Nonetheless, some mismatching of income and expense is tolerated under the law governing income tax accounting if the taxpayer uses the cash method of accounting consistently and makes no attempt to prepay expenses unreasonably or stockpile supplies at the end of the taxable year. See Ansley-Sheppard- Burgess Co. v. Commissioner, supra at 375; Van Raden v. Commissioner, 71 T.C. 1083, 1104 (1979), affd. 650 F.2d 1046 (9th Cir. 1981). In the instant case, Smith Floors has consistently used the cash method of accounting for tax purposes as permitted under section 446(c). The cash method of accounting for tax purposes is widely used throughout the contracting industry. See RACMP Enters., Inc. v. Commissioner, supra at 232, and cases cited therein. Furthermore, there is no evidence that Smith Floors ever attempted to prepay expenses unreasonably or accumulate excess supplies at the end of its taxable year. See RACMP Enters., Inc. v. Commissioner, supra at 233; Ansley-Sheppard-Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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