Read in its totality, RACMP provides the following:
The dissent in RACMP noted that the accrual method could be applicable to some aspects of the taxpayer's business and not to others.
Enterprises, Inc, 114 TC 16 (2000); the cases cited in notes 6-8, supra, are discussed in Tax Clinic, "Do Service Providers Have Inventoriable Merchandise?
The court distinguished this case from RACMP
, noting that the materials were indispensable to the services the taxpayer provided in that case, while, in Von Euw & L.
In an attempt to distinguish the case before it from RACMP
, the court stated that, unlike the concrete in RACMP
, the sand and gravel involved in the instant case was not "indispensable to and inseparable from the provision of a service.