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ALACARE HOME HEALTH SERVICES, INC. v. COMMISSIONER

Docket No. 9566-99.

81 T.C.M. 1794 (2001)

T.C. Memo. 2001-149

Alacare Home Health Services, Inc. v. Commissioner.

United States Tax Court.

Filed June 22, 2001.

Attorney(s) appearing for the Case

Robert C. Walthall, Birmingham, Alabama, for the petitioner.

Marshall R. Jones, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in petitioner's Federal income tax of $136,895 for 1995 and $58,726 for 1996 and accuracy-related penalties under section 6662(a) of $27,379 for 1995 and $11,745 for 1996.

After concessions,1 the issues for decision are:

1. Whether petitioner, an accrual-basis taxpayer, may expense in 1995 and 1996 the cost of assets that...

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