Herbert C. Haynes, Inc. - Page 2

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          year ending May 31, 1996 (FYE 1996), $527,216; and (3) for the              
          tax year ending May 31, 1997 (FYE 1997), $718,914.                          
               After concessions,2 the issue for decision is whether                  
          respondent abused his discretion by requiring petitioner to                 
          change its method of accounting from the cash receipts and                  
          disbursements method of accounting (cash method) to the accrual             
          method of accounting (accrual method).  Subsumed in this issue is           
          the question of whether petitioner is required to maintain                  
          inventories for tax purposes.                                               
                                     Background                                       
               The parties submitted this case fully stipulated pursuant to           
          Rule 122.  The stipulation of facts and the attached exhibits are           
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioner’s principal place of business was in Winn,            
          Maine.                                                                      
          Herbert C. Haynes, Inc.                                                     
               Petitioner is a closely held Maine corporation engaged in              
          the logging business.  Petitioner was incorporated in 1963.                 
          Before incorporation, Herbert C. Haynes, Sr. operated the logging           
          business as a sole proprietorship.  Herbert C. Haynes, Sr.,                 
          president and founder of petitioner, is the majority shareholder            
          of petitioner.  He owned between 97 and 89 percent of the stock             


               2  The parties filed a stipulation of settled issues                   
          resolving all other issues.                                                 





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