Summit Sheet Metal Co. - Page 4

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          September 30.  Petitioner's fiscal year ended on September 30 in            
          1986 and 1987.  In 1987, petitioner changed its fiscal year to              
          end on December 31.                                                         
               Petitioner had an initial capital investment of $65,579 in             
          1960 and had total assets of $4,183,222 on September 30, 1987.              
          Petitioner made a profit every year from 1960 to the year in                
          issue.  Petitioner had more jobs under contract in the year in              
          issue than in previous years.  The number of petitioner's                   
          employees increased greatly from 1984 to 1990.                              
               Petitioner's financial situation in fiscal years 1986 and              
          1987 was as follows:                                                        
                                                  FY 1986      FY 1987                
               Total sales                        $6,666,643   $8,621,838             
               Gross profit                       2,746,670    3,560,057              
               Ordinary income                                                        
                    before taxes                  803,997      893,236                
               Beginning total assets             3,407,735    3,761,574              
               Ending total assets                3,761,574    4,183,222              
               Beginning total equity             1,822,375    2,020,646              
               Ending total equity                2,020,646    3,391,012              
               Beginning total capital stock                                          
                    and paid-in stock or surplus                                      
                    less paid treasury stock      50,446       50,446                 
               Ending total capital stock                                             
                    and paid-in stock or surplus                                      
                    less cost of treasury stock   50,446       50,446                 
               Beginning accumulated                                                  
                    adjustments account           636,158      824,587                
               Ending accumulated                                                     
                    adjustments account           824,587    2,190,307                
               Beginning retained earnings        1,135,771    1,135,771              
               Ending retained earnings           1,135,771    1,135,591              
               Petitioner's success in the year in issue resulted in part             
          from an increase in housing construction in southern California.            





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