- -5
its fiscal year 1989 was $311,452. Petitioner's cost of goods
sold for garments that year, excluding U.S. customs duties
(customs duties), freight charges, and incidental fees was
$2,707,512.
For its fiscal year 1990, petitioner's gross sales of badges
was $1,425,185 and its cost of goods sold for badges (excluding
CDFC) was $1,015,493. For its fiscal year 1990, petitioner's
gross sales of garments was $6,289,071, which is composed of
$3,554,018 in documented sales and $2,735,053 in imputed sales.
The gross sales of garments is reduced by $2,476 for damaged or
missing goods. For its fiscal year 1990, petitioner's opening
garment inventory was $311,452. Garment purchases during that
year were $4,488,898, which is comprised of $4,223,566 in
documented purchases4 and $265,332 in imputed purchases. Closing
garment inventory was $219,232. Cost of goods sold for garments
for petitioner's fiscal year 1990 (excluding CDFC) properly
includable in inventory, was $4,581,118.
Mr. Roger Lee (Mr. Lee), the manager of Alexander Air
Express, Inc. (Alexander Air), prepared the customs documents for
petitioner during the years at issue. The shipping documents
were sent with the shipment if the shipment was by air, and, if
4 As in the computations for the taxable year ended Jan.
31, 1989, and as noted supra note 3, this figure does not
represent the sum of invoices introduced as evidence for that
year. As suggested by the parties, we find the amounts listed in
the stipulation of facts are appropriate.
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