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TYE June 30 Gross Receipts Direct Costs
1985 $751,058 $574,076
1986 1,431,377 953,362
1987 2,313,288 1,870,419
1988 2,900,805 12,053,624
1989 11,771,193 8,112,563
1We have deducted from the amount of direct costs the amount
of $4,521, which represents LTD's T-bill commission expense for
taxable year ended June 30, 1988, and which has been
recategorized in "Commissions - T-Bills." Accordingly, we
recalculate the direct costs for LTD's taxable year ended June
30, 1988, to be $2,053,624.
The breakdown of LTD’s "Direct Costs" for each taxable year is as
follows:8
TYE June 30 Direct Cost Amount
1985 IFF + MMA
1$574,076
1986 IFF 545,781
MMA 407,581
1987 IFF 472,938
MMA 475,268
Commissions 726
Byte 887,634
Casa interest 33,853
1988 IFF 690,978
MMA 949,087
Byte 413,559
1989 IFF 874,404
MMA 1,473,299
Asset Management Account 1,107
Eurodeposits 576,089
InverCedes 880,845
Liquid Assets 191,344
Term Deposits 4,626
Special Accounts 259,414
8
The parties stipulated total amounts that constitute direct
costs relating to LTD’s "Interest Income" category. The parties,
however, did not stipulate a breakdown of the direct costs, which
is necessary to our analysis, infra pp. 101-108, relating to
LTD’s interest income. We note that facts disclosed by the
Deloitte workpapers and the IRS revenue agent’s workpapers
provide the breakdown of the direct costs, which we set forth
herein and utilize in our analysis, infra pp. 101-108.
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