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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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