Total Health Center Trust, Bonnie Stejskal, Trustee, et al. - Page 6

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          Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 530 n.9                  
          (1979).                                                                     
               In this case, petitioners used a periodic inventory system             
          which requires an adjustment to inventory at the end of the year            
          to reflect the physical ending inventory count.  After performing           
          the physical count, petitioners’ accountant made an adjusting               
          journal entry for shrinkage, reflecting a $48,257.92 credit to              
          inventory and a $48,257.92 debit to product purchases.                      
          Petitioners’ accountant then used the adjusting journal entry to            
          reduce the trial balance of petitioners’ yearend inventory by               
          $48,257.92 and at the same time to increase the trial balance of            
          petitioners’ product purchases by $48,257.92.   The problem is,             
          there is nothing in the record to suggest, and petitioners do not           
          argue, that they actually purchased $48,257.92 of goods to                  
          replace the inventory that was lost.  And by including the                  
          $48,257.92 adjustment in purchases as well as ending inventory,             
          petitioners increased their cost of goods sold reported on                  
          Schedule C (and reduced gross income) by double the amount of               
          actual shrinkage their inventory suffered.  Thus, while it was              
          proper to reduce the ending inventory by the amount of shrinkage,           
          it was improper for petitioners to also increase the line 36                
          product purchases by the same amount.                                       
               Accordingly, we find that petitioners’ product purchases for           
          2000 were $366,574, and their cost of goods sold was $380,966               






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