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which oversees and coordinates the activities of the various
Nyingma organizations. Two directors, including Maitland, had
taught skillful means classes at the Nyingma Institute and served
as its dean.
Petitioner's market for its commercial printing business,
with the exception of the Amber Lotus division, encompassed the
greater San Francisco Bay Area. It did not advertise its
commercial printing business and primarily relied on customer
referrals and cold calls to obtain new customers. Petitioner had
a reputation as a high-quality, low-priced printer that provided
good customer service. Petitioner's Amber Lotus division
advertised through a variety of methods. The Amber Lotus
division accounted for approximately 7 percent of petitioner's
gross sales during the years in issue. Amber Lotus was started
by DM in 1986.
In taxable year 1991, petitioner reported gross sales of
$6,239,139 on its tax return. Respondent determined that
petitioner underreported its gross sales by $8,301. Petitioner
concedes an increase in its gross sales of $1,206. Petitioner
reported gross sales of $7,095 less than reflected on its books
and records because petitioner double counted sales on its books
and records by this amount. Petitioner had issued two invoices
to a customer for the same print job and recorded both invoices
as gross sales on its books and records. The customer paid both
invoices and then informed petitioner about the overbilling.
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