Ansley-Sheppard-Burgess Co. v. Commissioner
United States Tax Court
P, a subchapter C corporation, operates as a general contractor engaged in the construction business. P, a calendar year taxpayer, had always maintained its books and records, and reported its income for Federal tax purposes, on the cash receipts and disbursements method of accounting (the cash method). P's bonding company and banks, however, require P to maintain financial statements using the percentage of completion method of accounting (the percentage of completion…
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P, a subchapter C corporation, operates as a general contractor engaged in the construction business. P, a calendar year taxpayer, had always maintained its books and records, and reported its income for Federal tax purposes, on the cash receipts and disbursements method of accounting (the cash method). P's bonding company and banks, however, require P to maintain financial statements using the percentage of completion method of accounting (the percentage of completion method). R, inter alia, determined that P's method of accounting did not clearly reflect its income under sec. 446(b),…
1Opinion of the Court
Wells, Judge:
Respondent determined a deficiency in petitioner’s 1990 Federal income tax in the amount of $11,810 and an accuracy-related penalty under section 6662 in the amount of $2,362.1 After concessions by both parties, the sole issue for decision is whether respondent’s determination requiring that petitioner change its method of accounting from the cash receipts and disbursements method to the percentage of completion method was an abuse of discretion.
FINDINGS OF FACT
Some of the facts and certain documents have been stipulated for trial pursuant to Rule 91. The stipulated facts are…
2Cases cited27 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Lucas v. Kansas City Structural Steel Co.Supreme Court of the United States · 1930
- Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. CaldwellCourt of Appeals for the Second Circuit · 1953
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
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