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Several new market segment specialization program (MSSP) audit technique
guides have been issued by the IRS. These new guides address the following
industries: * Reforestation industry * Auto body industry and repair industry * Industries surrounding the Port of Houston * Gasoline retailers * Alaskan commercial fishing industry (two guides) * Beauty and barber shops The reforestation industry guide advises agents to watch out for nonfilers,
underreporting and unsubstantiated expenses, employment tax avoidance,
offsets of independent contractor income with business expenses resulting
in earned income tax credit, and return preparation by unlicensed preparers.
The auto repair guide instructs agents to focus on cash accounts, inventories,
depreciable assets, liability, and owner equity accounts. The guide also
advises agents how to analyze sales and understand the bookkeeping systems.
The Port of Houston guide advises agents on conducting audits of industries
associated with port activities such as ship and boat building and repair,
trucking, warehouses, and water transportation. The guide notes common
problem areas associated with the shipping business, including shipping-related
excise taxes, sourcing of income, and capital construction funds. After advising agents how to approach a gas retailing audit, that guide
provides agents with information on how the industry works. As pre-audit
techniques, they are advised to gather third-party information from oil
companies, compute purchases and sales, and compare to the return. The
guide suggests possible sources of additional income, and instructs agents
to focus on capital gains, rents and other expenses, rebates, imaging reimbursements
(loosely termed loans from oil companies to change signs or improve station
appearance), and a number of other specific issues. The guide also focuses
on problems with gas stations located on the borders of other countries
or Indian reservations. The first Alaskan fishing guide deals with issues such as the relationship
of the catchers with fish purchasers and processors and revenue flow considerations.
The guide also examines the reporting requirements pertaining to catchers'
employees and discusses the influence of non-U.S. interests on the U.S.
fishing industry. The second fishing guide examines the fish processing
and brokerage industries. The beauty and barber shop guide helps agents deal with a cash-based
business with few records. The guide advises agents to use financial status
audit techniques and analyze the cash flow to determine the extent of their
income probe. The guide includes a list of questions to ask during the
examination. MSSP audit guides are frequently reprinted by the major tax services
and are contained on some of the tax CD-ROM discs. You may obtain a copy
of any of the MSSP guides directly from the IRS by writing IRS Freedom
of Information Reading Room, P.O. Box 795, Ben Franklin Station, Washington
DC 20044. Requests of 100 pages or less are filled at no charge. A 15¢
per page charge applies to any excess over 100 pages. The FOI Reading Room
telephone number is (202) 622-5164. * Sources: MSSP audit guides for the industries noted. A number of enhancements to the NYSSCPA's online service, LUCA ONLINETM,
were announced at its November computer show. Topping the list is Internet
e-mail. It is now possible for those signed up on LUCA to not only communicate
among themselves using the LUCA messaging capability, but also to communicate
to anyone with an Internet e-mail address. As a result, all readers of
The CPA Journal who are on the net can communicate with the editors
via LUCA. Managing editor James Craig is jcraig@lucaonline.com. Editorial
assistant Michael Rosencrantz is mrosencrantz@lucaonline.com. We look forward
to our readers using this medium to be in touch with us. Other enhancements include the capability to download upgrades in the
LUCA software while connected to LUCA and the ability to print the LUCA
file currently being accessed. The schedule to open LUCA to all CPA Journal readers continues
on track for the spring of 1996. The full details will be made available
in the Journal and through a separate mailing. * For the past several years as part of the year-end tune-up by the editors,
there has been included a table of recently issued and effective accounting
and auditing pronouncements to assist in calendar year-end engagements.
This year that same table is presented as the final pages of News and Views
in this issue. * By Nicholas Cammarano, Jr., CPA, and James J. Klink,
CPA John Wiley & Sons, Inc. 330 pages; hard cover $105.00. Review by Alexander A.H. Bohtling, CPA, retired from Deloitte
& Touche Real Estate Accounting and Reporting provides a comprehensive
analysis of this very unique industry by two authorities in this field.
The book provides a clear overview of the complicated real estate industry
and of the specialized areas of GAAP that apply to it. The GAAP covered
include FASB statements and technical bulletins, AICPA industry audit and
accounting guides, AICPA statements of position, AcSEC practice bulletins,
emerging issues task force consensuses, and SEC requirements. The book consists of three parts‹accounting for real estate costs, accounting
for real estate sales, and accounting for investments in real estate ventures.
Covered are the various accounting aspects that are applicable to investors,
developers, merchant bankers, investment bankers, contractors, syndicators,
mortgage lenders, and brokers. Also included are the accounting principles
that apply to residential (including condominiums) and commercial properties.
The authors also point out that virtually all real estate transactions
are subject to clearance of environmental matters. The book is in its third edition. Nicholas Cammarano, Jr., CPA, is partner
in charge of Price Waterhouse LLP's real estate industry services group.
James J. Kirk, CPA, is retired from Price Waterhouse LLP and a former chairman
of that firm's real estate industry services group. In your reviewer's opinion, this book provides very useful guidance
to a wide range of potential readers including accounting executives in
the industry and CPAs in public practice. * The National Endowment for Financial Education, the umbrella organization
for a number of divisions that offer credentials and service marks in the
financial planning area (such as the certified financial planner credential)
recently announced the Chartered Mutual Fund Counselor Professional Education
Program, the successful completion of which will lead to the CMFCSM
designation. The program is jointly sponsored by NEFE and the Investment
Company Institute. Topics in the nine module, self-study format course
will range from risk and return to tax issues and retirement planning.
The course, according to NEFE, is designed to help a broad range of investment
professionals‹registered representatives, bank representatives, financial
planners, registered investment advisers, mutual fund wholesalers, and
mutual-fund desk representatives‹to better understand the technical aspects
of mutual funds. The cost of the course is $525. Those who successfully
complete the materials, pass the proctored final exam, and sign a code
of ethics and related declaration will earn the CMFC designation. * Child star Skye Bassett, who acted in Broadway shows, two made-for-TV
movies, and several TV show episodes‹all before turning 15‹earned over
$28,000, $56,000, and $21,000 respectively for the years 1985 through 1987.
Her parents failed to file tax returns for those years despite receipt
of appropriate W-2s. The IRS asserted civil payments for lateness and negligence against
Ms. Bassett and she fought the assessments, asserting she should be excused
from the penalties due to her youth and ignorance. The Tax Court noted
Bassett's parents' obligation to file her income taxes and their negligence
in failing to file for their daughter, but nonetheless rejected Bassett's
arguments. On appeal, the court noted that the IRC sections at issue did
not specify exactly whose lateness or negligence would trigger the penalties.
The Appellate Court distinguished IRS practices and court opinions that
held a taxpayer's illness or incapacity would provide reasonable cause
excuse from these penalties. In those cases, the court held the obligation
to file was on the incapacitated individual. Here the obligation to file
was on Bassett's parents, not Bassett herself, so her incapacity as a minor
provided no excuse. The road to stardom can be fraught with uncaring individuals
(and tax authorities, it seems). * Source: Bassett v. Commissioner, __ F.3d __ (2nd Cir. 1995).
LEXIS-NEXIS, a provider of comprehensive online services for accountants
and lawyers, in conjunction with the AICPA, recently announced a special
package for small firm AICPA members. The special program, available to
firms with 20 or fewer CPAs, includes access to the IRC, Treasury regulations,
case law, state tax materials, and AICPA accounting literature. It will
also give users the capability to search related business publications.
The special pricing offer runs through January 31, 1996. AICPA members
can contact LEXIS-NEXIS at (800) 227-9597, Ex. 4300 for information on
this online service. * Karl von der Heyden was recently appointed chair of the Financial Accounting
Standards Advisory Council (FASAC) to succeed E. Virgil Conway who left
that position to become chairman of the New York Metropolitan Transit Authority.
FASAC advises the FASB on its technical agenda and assists in setting priorities
for FASB's standard setting activities. With approximately 30 members,
FASAC intends to replicate the constituency that FASS serves. Von der Heyden is retired from RJR Nabisco Holdings Corp. * By Peter Barton, MBA, CPA, JD, and Clayton Sager, PhD,
University of Wisconsin-Whitewater In Ranciato v. Commissioner, the Second Circuit Court of Appeals
vacated and remanded a Tax Court decision denying losses of a retail store
because the owner lacked a profit motive. Ranciato is important
because the Tax Court's opinion is the first case where a court ruled that
a middle-income owner of a retail business lacked a profit motive. The
Court of Appeals ruled that the Tax Court misinterpreted congressional
intent regarding IRC Sec. 183, which was to disallow paper losses of wealthy
individuals who deliberately pursue unprofitable activities. IRC Sec. 183 specifies that if an activity is not engaged in for profit,
deductions are generally not allowed in excess of gross receipts. Therefore,
losses are disallowed. An activity is for profit if the taxpayer has "...an
actual and honest, even though unreasonable or unrealistic, profit objective."
The burden of proof is on the taxpayer unless the activity was profitable
for three of the last five years. To determine the taxpayer's intent, the regulations specify the following
nine nonexclusive factors: 1) whether the activity is operated in a businesslike
manner; 2) the expertise of the taxpayer or his or her advisors; 3) the
time and effort spent by the taxpayer; 4) the expectation that the activity's
assets may appreciate; 5) the taxpayer's record in other activities; 6)
the taxpayer's history of income or loss in the activity; 7) the amount
of any profit earned; 8) the taxpayer's financial status; and 9) elements
of pleasure or recreation in the activity [Reg. Sec. 1.183-2(b)]. These
factors must be applied on a case-by-case basis using "common sense
and an appreciation for the overall picture..." Anthony Ranciato opened South Sea Aquarium, Pets, and Pet Supplies in
1963. Anthony's mother worked full-time days at South Sea without compensation
since the 1960s. Anthony, his wife, and children worked nights and weekends
at the store. Anthony kept the books for South Sea in a "very disorganized
manner." He did not calculate gross profit percentages, operating
expenses, or the percentage of sales from animals verses supplies. Profitable until 1980, South Sea has incurred losses since then. During
the loss years, Anthony made minimal changes in operations and did little
advertising. He financed these losses from his other employment, savings,
and loans. Anthony worked full-time as an electrician or real estate agent
during 1985-87. He and his wife had combined gross income of $66,942 in
1985, $33,488 in 1986, and $44,221 in 1987. The IRS audited 1985-87, when
South Sea's losses were approximately $21,000-$28,000 per year and gross
receipts were $30,000-$39,000 per year. The IRS disallowed these losses
and assessed negligence and substantial understatement penalties. The Tax Court ruled that Anthony did not have a profit motive from 1985-87.
The court cited the following facts: He did not operate South Sea in a
businesslike manner; he neither had expertise nor hired experts in the
pet business; he did not adopt new methods to increase profitability; he
devoted little time to South Sea; the assets were not expected to appreciate;
and South Sea had years of losses. The Tax Court also sustained the penalties.
The Court of Appeals first agreed that the poor bookkeeping and the
failure to change operations in spite of continuing losses were evidence
that Anthony lacked a profit motive. However, the court ruled that it could
not affirm because the Tax Court overemphasized Anthony's negligent business
methods and did not consider the following factors: 1. Congress enacted Sec. 183 to disallow paper losses of wealthy individuals,
not actual losses of middle-class wage earners, even if they are inept
at operating a business; 2. Anthony's methods produced profits from 1963-80; and 3. The taxpayer's burden of proof is lighter for an activity, such as
a retail store, that is typically operated for profit, not recreation.
The Court of Appeals concluded that consideration of these factors "might
well yield a different result." Ranciato is important because if the Court of Appeals had affirmed,
every business with losses, poor bookkeeping, and minimal changes would
be vulnerable to disallowed losses. Also, it's not certain that the Tax
Court will reverse its opinion. Taxpayers are advised to maintain a good
accounting system and use it to make decisions. * Source: Ranciato v. Commissioner, 52 F.3d 23 (2d Cir. April 7,
1995); vacating and remanding T.C. Memo 1993-536. The Tax Equity and Fiscal Responsibility Tax Act of 1982, TEFRA, added
special rules allowing for the consolidated examination of partnership
returns. Previously, when the IRS audited a partnership, each partner could
attack any assessments. To represent the partnership and its owners in
a consolidated proceeding, TEFRA created the function of a Tax Matters
Partner, or TMP. The TMP is the general partner designated by the partnership
to serve in that role or if none, the general partner with the largest
interest in the profits of the partnership. In general, the consolidated partnership proceedings have worked well.
Then along came the LLC, which ordinarily is classified as a partnership
for tax purposes, but has no partners and no owners with general partner
liabilities. How should the IRS conduct an audit of an LLC under the consolidated
partnership proceedings? Who is the person to represent the LLC in the
audit? These were open questions until the October 27 issuance of proposed
regulations under IRC Sec. 6231(a)(7). The proposed regulations treat any member-managers of an LLC as general
partners and any other members as partners other than general partners.
The regulations define member-managers as those who are vested with the
continuing exclusive authority to make the management decisions necessary
to conduct the business for which the organization was formed. Where there
are no designated member-managers, all members will be treated as member-managers.
The proposed regulations also address certain technical difficulties
in determining which partner has the largest profits interest in determining
who is the TMP. * Source: Notice of Proposed Rulemaking PS-34-92, Fed. Reg. __
(10/30/95), containing Prop. Reg. sections 301.6231(a)(7) -1 and -2. The attorney-client privilege protects confidential communications pertaining
to legal advice between a client and an attorney. Such communications include
those between a client's attorney or a third person hired by the attorney
and the client. Note that the communications must be confidential and must
pertain to legal advice. Disclosure of a communication protected by the
attorney-client privilege cannot be compelled in court, unless certain
narrow exceptions apply. The work-product doctrine protects documents, interviews, statements,
mental impressions, and other tangible things prepared by an attorney in
anticipation of trial. Litigation frequently is anticipated well in advance
of the commencement of a lawsuit. "A litigant must demonstrate that
the documents were created 'with a specific claim supported by concrete
facts which would likely lead to [the] litigation in mind,' not merely
assembled in the ordinary course of business or for other nonlitigation
purposes," writes the Tax Court. Work-product doctrine protection is broader than attorney-client privilege
protection. The work-product doctrine protects items prepared by another
regardless of whether the client or the attorney engages the third party.
In another sense, the doctrine is weaker than the privilege because the
other party can force disclosure if there is a demonstration of "a
substantial need for the document in preparing [the other party's] case
for trial." The Tax Court's Bernardo decision is interesting because the
court analyzed the need to disclose documents produced by the taxpayer's
accountant under the requirements of both the attorney-client privilege
and the work-product doctrine. The case involved the charitable donation
of a sculpture called Omphalos (Greek for navel) to the Massachusetts Bay
Transportation Authority. The taxpayers deducted $593,000 over the course
of several years for the donation. IRS notified the taxpayers that its
Art Advisory Panel would be looking at the deduction and ultimately the
panel determined the sculpture was worth significantly less than claimed.
In the Tax Court litigation, the IRS sought to discover many communications
between the taxpayers and their attorneys and their accountants and appraisers.
None of the accountant communications were protected under the attorney-client
privilege. But nearly all the same accountant communications were protected
by the work-product doctrine after the point that litigation became likely.
This point came when the taxpayers were notified that the Art Advisory
Panel was brought into the picture. * Source: Bernardo v. Commissioner, __ TC __, Docket No. 24694-93
(June 20, 1995). RECENTLY ISSUED PRONOUNCEMENTS WITH CURRENT AND FUTURE EFFECTIVE DATESPRONOUNCEMENTS
SFAS No. 106, Employers' Accounting SFAS No. 107, Disclosures About Fair Value of Financial Instruments
of a Loan SFAS No. 114, Accounting by Creditors for Impairment of a Loan SFAS No. 116, Accounting for Contributions Received and Contributions
Made SFAS No. 117, Financial Statements of SFAS No. 118, Accounting by Creditors for Impairment of a Loan-Income
Recognition and Disclosures SFAS No. 119, Disclosure about Derivative Financial Instruments and
Fair Value of Financial Instruments SFAS No. 120, Accounting and Reporting SFAS No. 121, Accounting for the Impairment of Long-Lived Assets and
for Long-Lived Assets to Be Disposed of SFAS No. 122, Accounting for Mortgage SFAS No. 123, Accounting for Stock-Based Compensation FASB Interpretation No. 40, Applicability FASB Interpretation No. 41, Offsetting of Amounts Related to Certain
Repurchase and Reverse Repurchase Agreements SOP 94-1, Inquiries of State Insurance SOP 94-2, The Application of the Requirements of Accounting Research
Bulletins, Opinions of the Accounting Principles Board, and Statements
and Interpretations of the Financial Accounting Standards Board to Not-for-Profit
Organizations EFFECTIVE DATES For fiscal years beginning after December 15, 1992, except for plans
outside the U.S. and for If total assets are greater than $150 million: years ending after December
15, 1992. If total assets are less than $150 million: years ending after December
15, 1995. For fiscal years beginning after December 15, 1994. Earlier application
is encouraged. Previously For years beginning after December 15, 1994 and interim periods within
those fiscal years, except For annual financial statements issued for fiscal years beginning after
December 15, 1994, except for For fiscal years beginning after December 15, 1994, which is concurrent
with SFAS No. 114. Earlier application is encouraged. For fiscal years ending after December 15, 1994, except for entities
with less than $150 million in total assets in the current statement of
financial position, the effective date is for fiscal years ending after
December 15, 1995. Earlier application is encouraged. This statement need
not be applied to complete interim financial statements in the initial
year of application. For fiscal years beginning after December 15, 1995, with earlier application
encouraged. Initial application shall be reported retroactively through
restatement of all previously issued financial statements for comparative
purposes for fiscal years beginning after December 15, 1992. For fiscal years beginning after December 15, 1995, with earlier application
encouraged. For fiscal years beginning after December 15, 1995, with earlier application
encouraged. For calendar year 1996. Disclosure required in 1996 financial statements
about 1995 stock options. Disclosure provisions: years beginning after December 15, 1992. Other provisions: years beginning after December 15, 1994. For financial statements issued for periods ending after December 15,
1994. Earlier application is encouraged. Previously issued financial statements
may be restated to apply the provisions of this interpretation to the date
Interpretation 39 was first applied. For audits of financial statements performed on or after December 15,
1994. For fiscal years beginning after December 15, 1994, except for not-for-profit
organizations with less than $5 million in total assets and $1 million
in annual expenses, the effective date shall be for fiscal years beginning
after December 15, 1995. Earlier application is permitted. For organizations
that adopt FASB Statement No. 117 prior to its effective date, earlier
application is encouraged. PRONOUNCEMENTS SOP 94-3, Reporting of Related Entities SOP 94-4, Reporting of Investment SOP 94-5, Disclosures of Certain Matters in the Financial Statements
of Insurance Enterprises SOP 94-6, Disclosure of Certain Significant Risks and Uncertainties
SOP 95-1, Accounting for Certain SOP 95-2, Financial Reporting by SOP 95-3, Accounting for Certain Distribution Costs of Investment Companies
SAS No. 73, Using the Work of a Specialist SAS No. 74, Compliance Auditing SAS No. 75, Engagements to Apply Agreed-Upon Procedures to Specified
Elements, Accounts, or Items of a Financial Statement SAS No. 76, Amendments to SAS No. 72, SSAE No. 3, Compliance Attestation SSAE No. 4, Agreed-Upon Procedure GASB Statement No. 24, Accounting and Financial Reporting for Certain
Grants GASB Statement No. 25, Financial GASB Statement No. 26, Financial GASB Statement No. 27, Accounting for GASB Statement No. 28, Accounting GASB Statement No. 29, The Use of Not-for-Profit Accounting and Financial
Reporting Principles by Government Entities EFFECTIVE DATES For fiscal years beginning after December 15, 1994, except for not-for-profit
organizations with For financial statements for plan years beginning after December 15,
1994, except that the For annual financial statements for periods ending after December 15,
1994. For annual financial statements for periods ending after December 15,
1995. For fiscal years beginning after December 15, 1995. For fiscal years beginning after December 15, 1995. For annual financial statements for fiscal years beginning after December
15, 1995, and for interim For audits of periods ending on or after December 15, 1994. For audits of financial statements and of compliance with laws and regulations
for fiscal periods For reports dated after April 30, 1996. For letters issued pursuant to paragraph 9 after April 30, 1996. For engagements in which management's assertion is as of, or for a period
ending, June 15, 1994, or thereafter, unless otherwise indicated. For reports dated after April 30, 1996. For years beginning after June 15, 1995. For years beginning after June 15, 1996. For years beginning after June 15, 1996. For years beginning after June 15, 1997. For years beginning after December 15, 1995. Generally effective for years beginning after December 15, 1994. Cabintaxi, Corp. was formed on November 11, 1983 with only one shareholder.
Within a few days, the board voted to increase the number of shares and
sell stock to four additional persons. But no shares were ever issued.
While there was no written subscription agreement, there was an oral understanding
that the newly subscribed shares would be paid for and, in fact, all of
the shareholders paid for some or all of their stock before the S election
was filed. But only the original shareholder signed the election. The corporation incurred losses of $17,000 and $19,000 in its first
two years and passed them through to the entire shareholder group. The
Tax Court had held that all five shareholders were shareholders for purposes
of making the S election. And the Appellate Court, though mentioning that
the Tax Court's analysis was not as thorough as it would have liked, agreed.
So the S election was invalid and the early losses could not be passed
through to the shareholders. To throw salt on the wounds, both courts added that the early losses
were nondeductible anyway because the corporation had not entered its trade
or business at the time the deductions were taken. Proposed legislation presently before Congress would alleviate situations
such as Cabintaxi's by giving the IRS authority to retroactively permit
corporations to correct invalid elections. * Sources: Cabintaxi, Corp. v. Commissioner, __ F.3d. __ (7th Cir.
1995) and H.R. 2039 and S. 758, both entitled the S Corporation Reform
Act of 1995. TenKey, Inc., developer of Tax Shop tax preparation software,
is now offering accounting and tax professionals a page on the worldwide
web‹enabling them to tell their story to the over 30 million browsers of
the Net. TenKey provides accountants with a standard-size, full-color page
to include a photo, information about their experience, practice, areas
of expertise, and how those interested can contact them. The accountants' pages are connected to TenKey's home page located at
http://www.tenkey.com/. TenKey's home page also includes connections to
various other pages, including one featuring tax tips and tax planning
ideas, which the accountants are encouraged to contribute to (for which
they are given a hypertext reference back to his or her page). For more information, accounting and tax professionals should contact
TenKey at (800) 639-1040. * The November 1995 issue of The CPA Journal includes an article
by Professors Anthony Cocco and Daniel Ivancevich, "Recognition or
Footnote Disclosures of Compensatory Fixed Stock Options?" That article
suggests that if a company elects to recognize compensation expense for
fixed options, "an asset (prepaid compensation) is increased, along
with a corresponding increase in equity (options outstanding). These increases
will have an immediate impact on financial statement ratios that include
assets and/or equities." The authors then discuss the impact on the
debt-to-equity ratio and provide an example. Unfortunately, the authors' analysis of the accounting required by FASB
Statement No. 123 Accounting for Stock-Based Compensation, is incorrect.
Paragraph 30 of Statement No. 123 states: The compensation cost of an award of equity instruments to employees
shall be recognized over the period(s) in which the related employee services
are rendered by a charge to compensation cost and a corresponding credit
to equity (paid-in-capital) if the award is for future service. The FASB exposure draft (issued in June 1993) proposed that an asset
(prepaid compensation) be recognized at the date stock-based employee compensation
awards are granted. However, the Board ultimately agreed with many respondents
to the ED who said that future employee services (prepaid compensation)
do not represent probable future benefits that are controlled by the employer
at the date employee stock options are granted because employees are not
obligated to render the services required to earn their options. Therefore,
Statement No. 123 does not require recognition of prepaid compensation
at the grant date. Rather, the cost of the related services is accrued
and charged to compensation cost only in the period or periods in which
the related services are received. Because prepaid compensation is not
recognized at the grant date, the debt-to-equity ratio is not affected
at the grant date. On another point, the authors provide an example that illustrates the
effects of recognizing and then amortizing prepaid compensation, and the
last exhibit (Exhibit 3) focuses on comparative financial statements and
ratios after the service period has been completed. The authors conclude
that "prepaid compensation has been written off, reducing not only
total assets, but also retained earnings. Thus, by extension, stockholders'
equity decreases.... as well." That extension is incorrect for the financial statements after the service
period has been completed. Under the approach described by the authors,
compensation expense would reduce net income, retained earnings, and therefore
total stockholders' equity during the service period. However, after the
service period has been completed, the cumulative decrease in retained
earnings would exactly offset the cumulative increase in options outstanding.
As a result, total stockholders' equity would not change because of the
recognition of compensation expense for fixed options. Under the method required by Statement No. 123, cumulative changes in
retained earnings would offset cumulative changes in options outstanding,
so total stockholders' equity would not be affected by the recognition
of compensation expense for fixed options. * Robert J. Swieringa, Member Financial Accounting Standards Board [Editor's Note: Authors Cocco and Ivancevich realize that
changes in the final statement affected their article and furnished The
CPA Journal with an explanation. Mr. Swieringa's letter makes such an explanation
unnecessary.]
The
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