Eyefull Incorporated - Page 36

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          petitioner’s cash flow that they could not reasonably have                  
          expected to be able to finance the acquisitions without                     
          accumulation.  Therefore the acquisitions do not explain any part           
          of the accumulations in TYE 8/31/90 and TYE 8/31/91.                        
                                       Parking                                        
               Petitioner argues that its efforts to secure additional                
          parking to comply with County Building and Safety Department                
          requirements justify an accumulation of $500,000 in TYE 8/31/91             
          and TYE 8/31/92.  Respondent allowed no amount for this purpose.            
               Petitioner presented evidence of only one definite purchase            
          plan that would have warranted an accumulation in any of the                
          years at issue.  This was the plan to acquire the property that             
          petitioner is currently renting from MIC.  Once petitioner                  
          concluded leasing arrangements with MIC, its needs would have               
          been satisfied and no accumulation of funds to acquire property             
          for parking would be justified.  No evidence in the record fixes            
          the time of this transaction.  We can confidently infer, however,           
          that petitioner and MIC had reached an agreement before the end             
          of TYE 8/31/92, because the loan to MIC, which partly financed              
          MIC’s acquisition of the rental property, appears on petitioner’s           
          tax return for TYE 8/31/92.                                                 
               It is possible that petitioner had already abandoned its               
          plan to purchase the property before the end of TYE 8/31/91.                
          Krontz testified that petitioner paid MIC $8,000 per month, or              
          $96,000 per year under the lease.  On its tax return for TYE                




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