Cross Oil Company, Inc. - Page 14




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          1997.  Total income under the accrual method of accounting                  
          would be $343,704 for the year ended June 30, 1996, and                     
          $339,748 for the year ended June 30, 1997.  Thus, a change in               
          accounting method from the cash method to the accrual method                
          would yield a decrease in total income of $11,787, or                       
          approximately 3.4 percent, for the year ended June 30, 1996,                
          and an increase in total income of $75,448, or approximately                
          22.2 percent, for the year ended June 30, 1997.                             
               Petitioner’s taxable income for the year ended June 30,                
          1996, under the cash method of accounting was income of $20,649             
          and under the accrual method of accounting would be a loss of               
          $6,759, and a change in the method of accounting would yield a              
          decrease in taxable income of $27,408.  Petitioner’s taxable                
          income for the year ended June 30, 1997, under the cash method              
          of accounting was a loss of $16,340 and under the accrual                   
          method of accounting would be income of $59,108, and a change               
          in the method of accounting would yield an increase in taxable              
          income of $75,448.  Consistent with the cases that have been                
          decided on this issue, we conclude that the cash method and the             
          accrual method of accounting do not produce substantially                   
          identical results.                                                          
          Section 448                                                                 
               Petitioner considers itself a small business that is a                 
          “mom-and-pop” operation.  Petitioner has used the cash method               






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