- 12 - adequately establish and substantiate its purchases of scrap metal by cash. Petitioners also argue that the accuracy of Lyell Metal’s reported cost-of-goods sold is supported by the average gross profit margins within the scrap metal industry. The evidence in this case supports the basic accuracy of Lyell Metal's reported scrap metal purchases and reported cost- of-goods sold. For all the years in issue, Lyell Metal retained its canceled checks made payable to cash and its general inventory records. For 1992, Lyell Metal also retained copies of its receipts and its cash register tapes reflecting cash purchases of scrap metal, which records corroborate the basic accuracy of using, in this case, Lyell Metal's canceled checks made payable to cash to compute the total cash purchases of scrap metal for 1992 and thereby for the earlier years as well. For 1989 through 1991, Lyell Metal’s reported gross profit margins exceeded the average gross profit margins of similarly sized companies within the scrap metal industry. If respondent’s determinations for 1989 through 1991 were sustained, Lyell Metal would be taxed on the basis of gross profit margins that would be twice the industry average. Although the evidence indicates that Lyell Metal was a profitable company, it does not indicate that Lyell Metal was that much more profitable than other scrap metal companies, and it does not indicate that petitioners realized anywhere near the income charged to them by respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011