Cross Oil Company, Inc. - Page 10




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          required to maintain inventories because the Court found that               
          the sand and gravel were merchandise and an income-producing                
          factor in the taxpayer’s business.  The taxpayer was required               
          to report its taxable income on the accrual method of                       
          accounting.  The Court held that the Commissioner did not abuse             
          his discretion under section 446 when the Commissioner required             
          the taxpayer to change from the cash method to the accrual                  
          method of accounting.  See id.                                              
               Petitioner’s purchases were substantial and represent                  
          83 percent and 88 percent of its gross receipts in 1996 and                 
          1997, respectively.  Here, petitioner’s purchase of petroleum               
          products was substantial compared to its gross receipts and, as             
          such, those products are an income-producing factor in                      
          petitioner’s business.  Petitioner is required to use the                   
          accrual method of accounting, unless it is able to establish                
          that the cash and accrual methods yield substantially identical             
          results.                                                                    
          Substantial Identity of Results                                             
               Petitioner argues that a substantial identity of results               
          exists between its cash method of accounting and the accrual                
          method of accounting selected by the Commissioner.  Petitioner              











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