- 4 - required to pay interest on the deposits, and the funds were available for general use by BMP. At all relevant times, BMP used the cash method of accounting. Prior to the years in issue, BMP reported the downpayments received under the contracts as income in the year in which the payments were received. Beginning in 1996, pursuant to advice received from a newly hired accountant, BMP began reporting the payments as income in the year in which the contractual services were rendered. BMP did not file amended returns for prior years and did not request consent from the Secretary for a change in method of accounting. BMP filed a Form 1120S, U.S. Income Tax Return for an S Corporation, in each of the years in issue. In 1996, BMP reported a loss of $103,217. In 1997, BMP reported income of $9,741. Petitioners filed a joint Federal income tax return for each of the years in issue. In 1996, they claimed a loss of $103,217 for petitioner’s distributive share (100 percent) of BMP’s loss. In 1997, they reported $9,741 for petitioner’s distributive share (100 percent) of BMP’s income. In the statutory notice of deficiency, respondent determined that petitioners’ income as reported on their returns was understated by $87,660 in 1996 and $22,865 in 1997--the amounts of the deposits received by BMP but not included in income on its returns.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011