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Freightways Corp. & Subs. v. Commissioner, 113 T.C. 329,
332 (1999), revd. on other grounds and remanded 270 F.3d
1137 (7th Cir. 2001); Public Serv. Co. v. Commissioner,
78 T.C. 445, 452-453 (1982); Geometric Stamping Co. v.
Commissioner, 26 T.C. 301, 305-306 (1956); Fidelity
Associates, Inc. v. Commissioner, T.C. Memo. 1992-142.
As observed by this and other courts, the objectives of
financial and tax accounting are “vastly different”. E.g.,
Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 541
(1979); Public Serv. Co. v. Commissioner, supra; see also
United States v. Hughes Properties, Inc., 476 U.S. 593,
603 (1986). The primary goal of financial accounting is
to provide useful information to management, shareholders,
creditors, and other interested persons, and it is biased
toward understating the net income and assets of an
enterprise. See United States v. Hughes Properties, Inc.,
supra; Thor Power Tool Co. v. Commissioner, supra. On
the other hand, the primary goal of tax accounting is the
equitable collection of revenue and the protection of the
public fisc. See United States v. Hughes Properties,
Inc., supra; Thor Power Tool Co. v. Commissioner, supra.
As the Supreme Court has noted: “Given this diversity,
even contrariety, of objectives, any presumptive
equivalency between tax and financial accounting would be
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