Cross Oil Company, Inc. - Page 7




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          pursuant to section 1.466-1(c)(2)(i), Income Tax Regs., to                  
          reflect accurately the income of its business activities.                   
               Petitioner maintains that its cash method of accounting                
          more clearly reflects the income and expenses of its business.              
          Petitioner argues that respondent may not change its method of              
          accounting from one that clearly reflects income to another                 
          method of accounting because the Commissioner determines that               
          the alternate method will reflect petitioner’s income more                  
          clearly.                                                                    
               Section 446 provides:                                                  
               SEC. 446.  GENERAL RULE FOR METHODS OF ACCOUNTING.                     
                    (a) General Rule.–-Taxable income shall be                        
               computed under the method of accounting on the basis                   
               of which the taxpayer regularly computes his income in                 
               keeping his books.                                                     
                    (b) Exceptions.–-If no method of accounting has                   
               been regularly used by the taxpayer, or if the method                  
               used does not clearly reflect income, the computation                  
               of taxable income shall be made under such method as,                  
               in the opinion of the Secretary, does clearly reflect                  
               income.                                                                
                    (c) Permissible Methods.-–Subject to the                          
               provisions of subsections (a) and (b), a taxpayer may                  
               compute taxable income under any of the following                      
               methods of accounting-–                                                
                         (1) the cash receipts and disbursements                      
                    method;                                                           
                         (2) an accrual method;                                       
                         (3) any other method permitted by this                       
                    chapter; or                                                       
                         (4) any combination of the foregoing methods                 
                    permitted under regulations prescribed by the                     
                    Secretary.                                                        




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