- 36 - 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 TYEPage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
Last modified: May 25, 2011