- 13 - c. Cost of Sales 5/31/96 $1,477,361.00 5/31/97 $2,419,747.00 Since you are being required to use the accrual method of accounting, the values of your opening and closing inventories for the tax year ending 5/31/95 is $0.00 and $1,862,892.00. For the tax year ending 5/31/96, your opening and closing inventories are $1,862,892 and $1,477,361.00. For the tax year ending 5/31/97, your opening and closing inventories are $1,477,361.00 and $2,419,747. [Emphasis added.] The language regarding the adjustments to the cost of sales specifically refers to the value of petitioner’s inventories. We find respondent determined in the notice of deficiency that petitioner is required to maintain inventories. This is not a new issue. III. Whether Petitioner’s Accounting Method Clearly Reflects Income A. Applicable Law Respondent asserts that the cash method does not clearly reflect petitioner’s income. Under section 446,7 the 7 Sec. 446 provides in pertinent part: SEC. 446(a). General Rule.--Taxable income shall be computed under the method of accounting on the basis of which the taxpayer regularly computes his income in keeping his books. (b) Exceptions.--If no method of accounting has been regularly used by the taxpayer, or if the method used does not clearly reflect income, the computation of taxable income shall be made under such method as, in the opinion of the Secretary, does clearly reflect income. (c) Permissible Methods.--Subject to the provisions of subsections (a) and (b), a taxpayer may compute taxable income under any of the following methods of accounting-- (continued...)Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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