Alondra Industries, Limited, d.b.a. Accent Insulation Company and Subsidiaries, et al. - Page 10

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          Alondra, could and did take advantage of the housing boom just              
          then starting.  As a result, UCIC and Alondra were able to                  
          increase their sales.  In its 1978 corporate income tax return,             
          UCII reported gross receipts of $10,938,143.51, whereas the                 
          relevant returns for UCII, Alondra, and Edco for their 1987                 
          taxable years reported combined gross receipts of $25,115,417.6             

          6The figures are not strictly comparable.  The figures for                  
          Alondra and Edco are not available for the earlier year.  While             
          Alondra presumably had few or no sales in that year, Edco is                
          known to have been in existence and to have had employees.                  
          Subtracting Edco's gross receipts of $670,771 from the total for            
          1986-87 reduces the total to $24,444,646.                                   
               These figures should be adjusted to account for inflation.             
          The Consumer Price Index published by the Department of Labor is            
          the measure of inflation that is used in several sections of the            
          Code.  Secs. 1(f)(3)-(5), 32(j), 41(e)(5)(C), 42(h)(6)(G),                  
          63(c)(4), 68(b)(2), 132(f)(6), 135(b)(2)(B), 151(d)(4),                     
          513(h)(2)(C), 4001(e)(2).  In addition, it is the measure of                
          inflation that courts often use where the measure is not                    
          specified by statute, e.g., for the purpose of computing legal              
          costs awarded under the Equal Access to Justice Act or sec. 7430.           
          Jones v. Espy, 10 F.3d 690, 692 (9th Cir. 1993); Harris v.                  
          Sullivan, 968 F.2d 263, 265 (2d Cir. 1992); Bode v. United                  
          States, 919 F.2d 1044, 1053 n.8 (5th Cir. 1991).                            
               If we use the Consumer Price Index, $10,938,143.51 in 1978             
          amounts to $19,042,313.47 in 1987 dollars.  The 1986-87 total of            
          $24,444,646 represents only 28.37 percent growth over that                  
          figure.  If we take compounding into account, this corresponds to           
          annual growth of 2.8 percent if we consider the time until                  
          1986-87 to be 9 years (3.2 percent if we use 8 years).  If we use           
          the Producer Price Index, we get similar figures: $16,516,711.96            
          in 1987 dollars; total growth of 48.00 percent, representing 4.45           
          percent annual growth over 9 years.                                         
               For comparison, Mr. Munro's compensation received from                 
          Pertinax rose from $216,955 in 1978 to $596,316 in 1986 and                 
          $1,000,112 in 1987.  If we use the Consumer Price Index, $216,955           
          in 1978 amounts to $377,698.93 in 1987 dollars.  The 1987 amount            
          of $1,000,112 represents 164.79 percent growth over that figure.            
                                                             (continued...)           




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