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?," 31 The Tax Adviser 379 (June 2000) and in "Physician Practices and Proper Accounting Methods," p.
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.J.
Galedrige and RACMP
Enterprises represent the sound principle that Regs.
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." The court deemed the sand and gravel separable from the service provided, because the taxpayer did "not consume, alter, or add to the sand and gravel, ...