Zeeman Manufacturing Company, Inc. - Page 11

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          petitioner may avoid interest and grow from within, solid banking           
          and supplier relationships, and controlled expansion and                    
          improvement in a risky business.  Petitioner does not borrow                
          money and has not done so since 1965.  Petitioner's policy is to            
          finance current and future needs from within.                               
               In its statement, petitioner asserts that it has not                   
          permitted its earnings and profits to accumulate beyond the                 
          reasonable needs of its business.  Petitioner argues, to the                
          contrary, that its accumulated earnings and profits are                     
          inadequate to meet its future business requirements.  Petitioner            
          states that it reasonably accumulated $23,002,264 in taxable year           
          1991, $23,257,978 in taxable year 1992, and $24,218,583 in                  
          taxable year 1993.  We address individually each of the ten                 
          grounds asserted by petitioner as reasonable business needs.                
          Respondent has made no concessions as to any grounds.                       
               1.   Working Capital Needs                                             
               In its statement, petitioner sets forth working capital                
          needs of its business as a ground that it reasonably accumulated            
          $7,418,264 in taxable year 1991, $7,673,978 in taxable year 1992,           
          and $8,634,583 in taxable year 1993.  Petitioner calculated such            
          needs using the average business cycle method developed in                  
          Bardahl Manufacturing Corp. v. Commissioner, T.C. Memo. 1965-200            
          (the Bardahl formula).                                                      
               Respondent argues that petitioner used an unconventional               
          method of computing the Bardahl formula and that petitioner's               




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