ASAT, Inc. - Page 13

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          Internal Revenue Manual procedures during the examination in this           
          case.                                                                       
               During the examination, Ms. Hamilton was also auditing                 
          another taxpayer that provided services similar to those provided           
          by petitioner, that is, selling the integrated circuit assembly             
          services of its foreign parent.  The other taxpayer received a              
          commission rate ranging from 11 to 15 percent.  The other                   
          taxpayer had three separate divisions.  Two of these divisions              
          were distributors of goods.  The third division was similar to              
          petitioner in that it found customers for the integrated circuit            
          assembly services of the foreign parent.  There was separate                
          accounting for each activity.  The division which found customers           
          for the services of the foreign parent had no warehousing                   
          expenses and no inventory.                                                  
               To assist in her determination as to the appropriate amount            
          of petitioner's gross profit spread, Ms. Hamilton consulted with            
          an economist employed by respondent, Ron McGinley.  During the              
          examination, Ms. Hamilton related to Mr. McGinley what                      
          petitioner's representatives told her about petitioner's business           
          and what petitioner's functions were with respect to its sales.             
          Mr. McGinley provided Ms. Hamilton with information from the                
          examination of another taxpayer presenting an issue concerning              
          services rendered similar to that in petitioner's case.  Mr.                
          McGinley advised Ms. Hamilton that, based upon the functions                






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