- -20
Petitioner devotes much of its brief to argument that it is
being penalized because of its lack of adequate records.
However, the duty is on petitioner to maintain adequate records
and, in determining items affecting its income tax, the lack of
such records should weigh heavily against petitioner.
Petitioner's computations in lieu of its records do not comport
with facts in the record or with reason. We have determined
amounts we consider very reasonable for customs duties, freight,
and other fees with respect to petitioner's sales in the years
here in issue based on the facts in this record. We consider
these amounts to represent reasonably the amounts paid by
petitioner in each year. However, the fact that it was necessary
to reconstruct the amounts paid by petitioner for customs duties,
freight charges, and other fees is due to petitioner's failure to
keep adequate records as required by statute.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011