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MOORE v. COMMISSIONER

Docket No. 8729-78.

45 T.C.M. 557 (1983)

T.C. Memo. 1983-39

Jerry C. Moore and Billie F. Moore v. Commissioner.

United States Tax Court.

Filed January 24, 1983.

Attorney(s) appearing for the Case

Alfred Sallinger, John D. Copeland and Paulette Mueller, 1200 Republic Natl. Bank Bldg., Dallas, Tex., for the petitioners. Gary A. Benford, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in income tax of petitioners, Jerry C. Moore and Billie F. Moore, for the calendar years 1972 and 1973 in the respective amounts of $281,917 and $116,833.

The issues for decision are as follows: (1) whether respondent properly determined under section 446(b)1 that petitioners should use an accrual method of accounting rather than...

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