Apollo Overseas International, Inc. - Page 4

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          Taiwan).  Apollo Taiwan was owned by Ms. Chiou's father, Chiou              
               For its fiscal year ending January 31, 1989 (fiscal year               
          1989), petitioner's gross sales of badges were $734,744 and its             
          cost of goods sold for these badges (excluding customs duties and           
          freight charges (CDFC)) was $566,176.  For its fiscal year 1989,            
          petitioner's opening garment inventory was $171,762, plus CDFC in           
          the amount of $27,908.  For that same year, gross sales of                  
          garments was $3,713,466, which is composed of $1,398,151 in                 
          documented sales, $1,397,100 in deemed sales, and $918,216 in               
          imputed sales.1  The above gross sales of garments is reduced by            
          $163,571 for damaged or missing imported goods.  For its fiscal             
          year 1989, petitioner's garment purchases were $2,847,202, which            
          is composed of $2,650,012 in documented purchases2 and $197,1903            
          in imputed purchases.  Petitioner's closing garment inventory for           

          1  "Documented sales" represent garment sales, the sales                    
          invoices for which can be matched with items in opening inventory           
          or items purchased during the year.  "Deemed sales" are those               
          garment sales for which there are sales invoices but no matching            
          purchase invoices.  "Imputed sales" are those garment sales of              
          items that were either included in opening inventory or purchased           
          during the year and did not appear in ending inventory, but for             
          which there are not complete matching sales invoices.                       
          2  The sum of the purchase invoices for the fiscal year 1989                
          is $2,643,519.36.  The parties disagree as to why this number               
          does not equal the amount in the stipulation, but both parties              
          apparently have agreed to use the number in the stipulation as              
          shown by this finding, despite the mathematical error.                      
          3  Though the stipulation lists this figure as $107,190,                    
          both parties have stated on brief that the correct figure is                

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