Apollo Overseas International, Inc. - Page 5

                                        -  -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.                                   




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011