Calderwood Distributors Inc, a calendar-year C corporation that is not a tax shelter, sells merchandise and currently uses the accrual method. For 2024 it wants to know whether it qualifies as a small business taxpayer that may use the cash method and be exempt from the uniform capitalisation rules. Its average annual gross receipts for the three prior tax years (2021, 2022 and 2023) are 26,000,000 dollars. Applying the inflation-adjusted gross receipts test for the 2024 tax year, may the corporation use the cash method?
- ANo, because any C corporation that holds inventory is barred from the cash method and must use the accrual method regardless of the size of its gross receipts.
- BNo, because its average annual gross receipts of 26,000,000 dollars exceed the 25,000,000 dollar small business taxpayer threshold and so it fails the gross receipts test.
- CNo, because a C corporation may use the cash method only if its average annual gross receipts are below 5,000,000 dollars, a limit the corporation clearly exceeds.
- DYes, because its average annual gross receipts of 26,000,000 dollars are at or below the inflation-adjusted 30,000,000 dollar gross receipts threshold for the 2024 tax year. Correct
Why A is wrong: The old rule that inventory forces the accrual method was relaxed for small business taxpayers; a C corporation under the gross receipts threshold may use the cash method even with inventory, so this overstates the restriction.
Why B is wrong: The 25,000,000 dollar figure is the unindexed base amount; the threshold is adjusted for inflation and is higher for 2024, so comparing against the base rather than the indexed figure wrongly disqualifies the corporation.
Why C is wrong: The 5,000,000 dollar C corporation limit is a separate, older rule that the small business taxpayer exception supersedes; applying that low threshold here misidentifies the governing test and gives the wrong conclusion.
Why D is correct: For tax years beginning in 2024 the inflation-adjusted gross receipts threshold is 30,000,000 dollars, and the corporation's 26,000,000 dollar average is below it, so it is a small business taxpayer eligible for the cash method.