Edward G Smith and Jan M. Smith - Page 13




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          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-               






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