Eyefull Incorporated - Page 58

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               25. See note 4.                                                        
               26. We use the year-end balance stated on Form 1120,                   
          Schedule L, and the worksheet accompanying the notice of                    
          deficiency.  For reasons that were not explained, in her                    
          Bardahl computations for trial respondent used the much higher              
          balance for the beginning of the year, which has the effect of              
          increasing available net liquid assets and, ultimately,                     
          accumulated earnings tax liability.  Thus, the revision would               
          constitute “new matter” for which respondent offered no proof.              

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