Vanguard Recording Society v. Commissioner of Internal Revenue

J. JOSEPH SMITH, Circuit Judge:

Taxpayer is a New York corporation which keeps its books on an accrual basis. From 1957 to 1963 taxpayer’s accounts payable control account exceeded the total of the individual accounts payable by $8,475.75. Taxpayer was aware of this, but allowed the discrepancy to be carried on its books (noted only by a pencil entry in the control account) until it had to have a certified accountant’s report, in which no discrepancies could be carried. So for the tax year ending March, 1963, taxpayer debited the accounts payable control account so it would accord with the…