- 38 - 1982, supra table 5, payments by Kenmore to the refineries for the fuel charged by Broskin are included in Kenmore’s purchases for its fiscal 1981 and fiscal 1982. Supra table 6. As a result, amounts deposited into Kenmore’s Account that came from Broskin are offset by payments from Kenmore’s Account to the refineries for fuel charged by Broskin, and thus the amounts deposited into Kenmore’s Account that came from Broskin are properly includable in Kenmore’s gross receipts and do not explain Kenmore’s unreported income. This may be illustrated by a transaction to which Bohn testified. Kenmore’s one-write records show that on December 1, 1981, Kenmore wrote a check to American Refining Group, Inc., in the amount of $53,887.70. Evidently, the original bill was in the amount of $54,432, and Kenmore took advantage of a one- percent discount ($544.30) for timely payment. The one-write records show a December 1, 1981, $54,432 deposit to Kenmore’s Account. Evidently, Broskin paid $54,432 to Kenmore, which amount was deposited into Kenmore’s Account. Although the bank deposits method may arguably be said to overstate Kenmore’s gross receipts by $54,432, this is offset by the Kenmore payment to American Refining Group, Inc., which (under that line of reasoning) overstates Kenmore’s cost of purchases by $53,887.70. Under the bank deposits method as applied in the instant cases, see supra tables 4 through 7, only $544.30 of taxable income results from the above-described transaction; that is the correctPage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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