Legal Opinion

Applied Communications, Inc. v. Commissioner

United States Tax Court

Decided August 30, 1989No. Docket No. 5449-87UnpublishedCited by 7 opinions

P began as a custom computer software business and, based upon its accountant's recommendation, reported its income (derived mainly from services) on the cash method of accounting for financial and tax purposes. Two years later when P began selling hardware, it reported hardware income on the accrual method of accounting for financial and tax purposes, without changing from the cash method for its software generated revenue.

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P began as a custom computer software business and, based upon its accountant's recommendation, reported its income (derived mainly from services) on the cash method of accounting for financial and tax purposes. Two years later when P began selling hardware, it reported hardware income on the accrual method of accounting for financial and tax purposes, without changing from the cash method for its software generated revenue. Several years later P, for financial purposes, changed to the accrual method for reporting its software generated income. At about the same time P's business was…

1Opinion of the Court

APPLIED COMMUNICATIONS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Applied Communications, Inc. v. Commissioner

Docket No. 5449-87

United States Tax Court

T.C. Memo 1989-469; 1989 Tax Ct. Memo LEXIS 469; 57 T.C.M. (CCH) 1473; T.C.M. (RIA) 89469;

August 30, 1989

P began as a custom computer software business and, based upon its accountant's recommendation, reported its income (derived mainly from services) on the cash method of accounting for financial and tax purposes. Two years later when P began selling hardware, it reported hardware income on the accrual method of…

2Cases cited25 opinions

  1. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  2. Commissioner v. HansenSupreme Court of the United States · 1959
  3. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  4. Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
  5. Schulde v. CommissionerSupreme Court of the United States · 1963

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3Cited by7 opinions

  1. Continental Illinois Corp. v. CommissionerUnited States Tax Court · 1989
  2. Ford Motor Co. v. CommissionerUnited States Tax Court · 1994
  3. Isaacs v. Comm'rUnited States Tax Court · 2015
  4. NEMETSCHEK NORTH AMERICA, INC. v. COMMISSIONERUnited States Tax Court · 2001
  5. Osteopathic Med. Oncology & Hematology, P.C. v. CommissionerUnited States Tax Court · 1999

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