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30-90), No. 2 reported gross receipts of $248,662, and for its
taxable year ended April 30, 1991 (5-01-90 to 4-30-91), reported
zero gross receipts. In the notice of deficiency respondent
combined the gross receipts of petitioner and No. 2; respondent
increased petitioner's gross receipts for its fiscal year ended
July 31, 1989, from $614,178 to $750,112 for an increase of
$135,934, and for its fiscal year ended July 31, 1990, increased
petitioner's gross receipts from $513,413 to $714,322 for an
increase of $200,909. Petitioner stipulated to these additional
gross receipts in the amounts of $135,934 and $200,909 for those
respective years.
The increased gross receipts of $135,934 for the taxable
year ended July 31, 1989, and $200,909 for the taxable year ended
July 31, 1990, to which petitioner stipulated, total $336,843;
that total amount exceeds No. 2's gross receipts of $248,662 by
exactly $88,181. While the record does not show how or on what
basis No. 2's gross receipts of $248,662 were allocated between
the two taxable years ending July 31, 1989 and 1990, it is clear
that the additional gross receipts to which petitioner stipulated
included all of No. 2's gross receipts plus the $88,181 August
1990 bank deposits that were shifted from petitioner's taxable
year ended July 31, 1991 to its taxable year ended July 31, 1990.
The parties' stipulation of facts covers all of the gross
receipts of both petitioner and No. 2. The Court holds
petitioner to the stipulation and is not persuaded that there is
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