- 11 - claims that its receivables, inventory, and payables have remained consistent from the inception of the business and that it has not attempted to distort its income by unreasonably prepaying expenses, purchasing supplies in advance, or delaying the receipt of payment from its customers. Respondent argues that petitioner has failed to demonstrate that there is a substantial identity of results between the cash method and accrual method of accounting based on the differences in income between the cash method and accrual method of accounting. The substantial identity of results test is a judicial creation that was first articulated in Wilkinson-Beane, Inc. v. Commissioner, supra. In Wilkinson-Beane, Inc., a cash-method taxpayer who was required to maintain an inventory and, thus, report income on the accrual basis argued that the difference in income that was determined by the method it used and the method selected by the Commissioner was negligible. The Court of Appeals held that, where the Commissioner has determined that the accounting method that is used by a taxpayer does not clearly reflect income, "the taxpayer must demonstrate substantial identity of results between his method and the method selected by the Commissioner" in order to prevail. Id. at 356. In Ansley-Sheppard-Burgess Co. v. Commissioner, supra at 377, this Court held that a taxpayer that is required to use the inventory method of accounting must meet the substantialPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011