Southern Boiler Sales & Service, Inc. - Page 8

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          and by $200,909 for its taxable year ended July 31, 1990, for               
          total gross receipts of $750,112 for 1989 and $714,322 for 1990.            
          Petitioner stipulated to the additional gross receipts for each             
          year.  The $135,934 plus the $200,909 totals $336,843, which                
          includes the full $248,662 of No. 2's gross receipts plus                   
          $88,181.  Respondent determined that $88,181 of gross receipts              
          deposited in petitioner's bank account during August of 1990                
          should be removed from petitioner's taxable year ended                      
          July 31, 1991, and included in its taxable year ended July 31,              
          1990.  The deficiency notice shows that the gross receipts for              
          the taxable year ended July 31, 1991 were reduced by $88,181.               
               The deficiency notice allocated the $47,754 of No. 2's costs           
          of sales to petitioner, $39,581 to its taxable year ended                   
          July 31, 1989, and $8,173 to its taxable year ended July 31,                
          1990.  The record does not indicate the basis for the allocation.           
          That adjustment increased petitioner's deductions for costs of              
          sales from $210,441 to $250,022 and from $85,457 to $93,630 for             
          those years, respectively.  Petitioner has not challenged that              
          adjustment.                                                                 
               Of the $3,861 of interest income No. 2 reported on its                 
          return for taxable year ending April 30, 1990, the deficiency               
          notice allocated $1,336 to petitioner's income for its taxable              
          year ended July 31, 1989, and $2,525 to its taxable year ended              
          July 31, 1990, thus increasing petitioner's total interest income           
          to $2,671 and $4,275 for those respective years.  The record does           




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