Meadows Funeral Home, Inc., your client, is an accrual basis taxpayer that sells "pre-need" funeral contracts. Under these contracts, the customer pays in advance for goods and services to be provided at the contract beneficiary's death. These payments are refundable at the contract purchaser's request, pursuant to state law, at any time until the goods and services are furnished. Tranquility, consistent with its financial accounting reporting, includes the payments in income for the year the funeral service is provided.AnIRS agent insists that the contract payments constitute prepaid income subject to tax in the year of receipt. Your client believes the amounts involved are tax-deferred customer deposits.

Please provide anTax File Memorandumto Meadows that contains your tax advice about how the issue should be resolved. The client's address is 444 River Road, Atlanta, Georgia 3003