Stuart and Betsy Bobry, et al. - Page 7

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            The receipts and canceled checks reflected the same total cash                              
            purchases of scrap metal for the year.                                                      
                  On some occasions, Lyell Metal paid cash for expenses                                 
            unrelated to the purchase of scrap metal.  For example, Lyell                               
            Metal paid cash for the services of an electrician.                                         
                  On February 21, 1992, respondent requested of Lyell Metal in                          
            writing that Lyell Metal obtain, record, and retain for                                     
            respondent detailed information (namely, names, addresses, Social                           
            Security numbers, and employee identification numbers)                                      
            identifying the customers from whom Lyell Metal purchased scrap                             
            metal by cash.  As of the date of trial, Lyell Metal has not                                
            complied with respondent’s request.                                                         
                                                                                                       
            Lyell Metal’s Reported Gross Profit Margins, Federal Income Tax                             
            Returns, and Respondent’s Audits                                                            
                  Based on the evidence before us, from 1989, 1990, and 1991,                           
            Lyell Metal’s gross profit margins (as reflected by gross revenue                           
            and cost-of-goods sold as reported on Lyell Metal’s tax returns)                            
            exceeded the average gross profit margins of similarly sized                                
            scrap metal companies.  For 1992, the record does not reflect an                            
            average gross profit margin for scrap metal companies.                                      
                  For 1989 through 1991, the following schedule reflects Lyell                          
            Metal’s gross revenue and total cost-of-goods sold as reported on                           
            its Federal income tax returns, Lyell Metal’s gross profit                                  
            margins based on the tax returns as filed, and the average gross                            






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