-5-
Fiscal After-tax Dividends
Year Assets Gross Revenue Gross Profit Net Income Paid
1978 $13,797,060 $13,261,695 $1,581,772 $476,805 ---
1979 10,651,010 21,321,960 2,770,522 1,099,341 $255,063
1980 7,367,576 705,640 (1,048,785) 298,798 ---
1981 13,225,920 40,852,715 4,550,930 1,455,211 ---
1982 7,015,414 10,244,505 (102,826) (489,941) ---
1983 5,931,770 1,213,983 (232,193) (135,116) 631,785
1984-
1986 3,424,358 8,945,181 960,902 (859,615) 1,082,164
26,019,914
1987 2,946,961 559,312 114,798 (139,525) ---
Total N/A 123,124,905 N/A 11,705,958 1,969,012
1
The full amount of the 1987 compensation paid to Mr. Leonard,
as well as the amount of the distribution of a 1985 in-kind dividend
that had been treated as a loss for financial accounting purposes,
have been taken into account in calculating petitioner's aggregate
after-tax net income. The aggregate before-tax net income was
slightly over $6 million.
Petitioner reported the following amounts on its Forms 1120F,
U.S. Income Tax Return of a Foreign Corporation, for fiscal years
1979-84, and Forms 1120, U.S. Corporation Income Tax Return, for
1985-87:
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