- 2 - it was an abuse of respondent’s discretion, under section 446, to require petitioner to change from the cash method of accounting to the accrual method of accounting in order to reflect clearly the income of petitioner’s oil and gas business. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioner Cross Oil Company, Inc., is an Oklahoma corporation with its principal place of business in Ponca City, Oklahoma. Petitioner is engaged in the wholesale and retail sale of gasoline, diesel fuel, oil, and other petroleum products. Petitioner sells and distributes a premanufactured product to its customers. Petitioner’s sales are mostly in bulk form, in which large orders of petroleum products are loaded at the local refinery and delivered directly to the customer by petitioner or by a contract truck hired by petitioner. Petitioner also maintains an inventory, of generally not more than a 2-1/2 week supply of products, at its business location. The inventory that is available for sale at petitioner’s place of business is either delivered to or picked up by the customers. Petitioner’s purchases of petroleum products are made as a 10-day net salePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011