- 4 - Petitioner’s total income (i.e., gross income less cost of goods sold) that was computed under the cash method and accrual method of accounting, and the differences in amounts and differences as percentages, are as follows: Amount Percentage Year Ended Cash Method Accrual MethodDifference Difference June 30, 1996 $355,491 $343,704 ($11,787) (3.4) June 30, 1997 264,300 339,748 75,448 22.2 Petitioner’s taxable income (i.e., total income less deductions) that was computed under the cash method and accrual method of accounting, and the differences in amounts, are as follows: Amount Year Ended Cash Method Accrual Method Differenc e June 30, $20,649 ($6,759) ($27,408) 1996 June 30, (16,340) 59,108 75,448 1997 Following an audit, the Commissioner sent a notice of deficiency to petitioner that stated: “It is determined the accrual method of accounting more clearly reflects income than your current ‘Cash Basis’ method of accounting.” OPINION The issue presented is whether 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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