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Taiwan). Apollo Taiwan was owned by Ms. Chiou's father, Chiou
Wan-I.
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
$197,190.
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