- 3 - findings by this reference. At the time the petition in this case was filed, petitioner's principal place of business was located in Alviso, California. Petitioner keeps its books and records on the cash method and has always done so. It files its Federal income tax return using a fiscal year ending June 30. Petitioner is a corporation engaged in the business of asphalt paving and related services. Potential customers contact petitioner, asking for an estimate to perform asphalt paving work. Petitioner sends an estimator to examine the area to be paved, to measure it, and to determine the approximate amount of asphalt needed for the job. The estimator also considers the equipment, number of workers, and time required to complete the job. Two jobs could require the same amount of asphalt but have different costs. For instance, it requires more time, and possibly different equipment, to pave a parking lot with structures on it than a wide-open parking lot. The estimator prepares a "proposed worksheet", which indicates all the factors involved in estimating a bid price for a job. During the years in issue, the proposed worksheet had three cost columns: Equipment, labor, and materials. The equipment column had spaces to enter a description of the equipment required, the hours required, and the hourly cost of the equipment. The labor column had spaces to enter the laborers' names, the hours required, and the hourly cost of each laborer. Finally, the materials column had spaces for thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011