Cross Oil Company, Inc. - Page 13




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          Commissioner, T.C. Memo. 1997-311 (taxpayer failed to meet the              
          substantial identity of results test where taxable income under             
          the cash method of accounting was $54,128 and under the accrual             
          method of accounting would be $328,549, and where gross                     
          receipts under the accrual method of accounting increased by                
          $349,769); Thompson Elec., Inc. v. Commissioner, T.C. Memo.                 
          1995-292 (cash method did not produce substantial identity of               
          results where taxable income under cash method is $138,418 and              
          $135,958 and under the accrual method is $331,925 and $289,039,             
          respectively); J.P. Sheahan Associates, Inc. v. Commissioner,               
          T.C. Memo. 1992-239 (taxpayer failed to meet substantial                    
          identity of results test where variations in taxable income                 
          ranged from a decrease in income of $111,263 to an increase in              
          income of $99,055); Surtronics, Inc. v. Commissioner, T.C.                  
          Memo. 1985-277 (cash method did not produce substantially                   
          identical results to the accrual method where the use of the                
          accrual method would increase net income by $132,437 and                    
          $73,673 and increase gross receipts by $148,212 and $92,771,                
          respectively).                                                              
               Petitioner produced several comparative charts that                    
          summarized the differences in income between the cash method                
          and accrual method of accounting.  Petitioner’s total income                
          under the cash method of accounting was $355,491 for the year               
          ended June 30, 1996, and $264,300 for the year ended June 30,               






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