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Ronning v. Commissioner: Eleventh Circuit Finds Plaintiff Did Not Provide Sufficient Evidence to Show He Was an Accrual-Method Taxpayer

Michael Miaoulis*

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In Ronning v. Commissioner, the U.S. Court of Appeals for the Eleventh Circuit addressed the differences between an accrual-method taxpayer and a cash-method taxpayer.  After the IRS determined that a taxpayer, Scott Ronning (“Ronning”), owed a significant amount in back taxes and penalties, the Tax Court calculated the amount owed based on a finding that Ronning was a cash-method taxpayer. Considering this evidence, the Eleventh Circuit held that the “Tax Court’s finding that Ronning was a cash-method taxpayer was not clearly erroneous. With their decision in Ronning, the court showed deference to the decision of the Tax Court.  However, in its step-by-step analysis, the Eleventh Circuit made clear that a taxpayer could provide sufficient evidence for the court to determine the Tax Court erred in its determination of a taxpayer’s methodology.

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