Falk v. Commissioner
United States Tax Court
A revenue agent investigating a partnership return of income for 1952 told the partnership's certified public accountant and one of the partners that the proper method of keeping the records and filing the 1954 return of income of the partnership was on an accrual basis.
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A revenue agent investigating a partnership return of income for 1952 told the partnership's certified public accountant and one of the partners that the proper method of keeping the records and filing the 1954 return of income of the partnership was on an accrual basis. After consulting an attorney, the certified public accountant prepared the 1954 partnership return on an accrual basis and had a notation put thereon that this was done in accordance with the instructions of a revenue agent. In 1959 the partners timely filed with the district director a statement that the partnership elected…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioners’ income tax for the years and in the amounts as follows:
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The issues for decision are:(1) Whether petitioners initiated the change in the year 1954 from the cash to an accrual method of accounting in computing the net income of a partnership of which two of them were the partners.(2) If petitioners did initiate the change in the partnership’s method of accounting, did they file a proper election under the provisions of section 481(b) (4) (B) of the Internal Revenue Code of 1954 to treat adjustments for years prior to…
2Cases cited11 opinions
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