Gustafson's Dairy, Inc. - Page 26

                                        -26-                                          
          percent of its net after-tax income.  During the years at issue,            
          petitioner's net income after taxes was $1,095,848 for fiscal               
          year 1987, $1,877,983 for fiscal year 1988, and $1,058,277 for              
          fiscal year 1989.  Petitioner paid dividends of $100,000,                   
          averaging about 7.44 percent of net after-tax income, in each of            
          those years.                                                                
               Petitioner's book income, taxes paid, book net income after            
          taxes, dividends paid, and percentage of net income paid as                 
          dividends for fiscal years 1982 to 1989 were as follows:                    


                             INCOME, TAXES PAID, AND DIVIDENDS                        
                                                                Percentage of         
            Tax                             Book net             net income           
            year   Book net               income after Dividends  paid as             
          ending    income   Federal taxes   taxes      paid     dividends            
          3/31/82  $1,483,898   $586,418    $897,480      0        0.0                
          3/31/83  2,244,000    725,508    1,518,492   $299,421    19.7%              
          3/31/84   642,513     85,440      557,073    100,057     18.0               
          3/31/85  3,002,591   1,245,977   1,756,614   99,966      5.7                
          3/31/86  1,738,731    693,338    1,045,393   100,000     9.6                
          3/31/87  2,029,349    933,501    1,095,848   100,000     9.1                
          3/31/88  2,980,721   1,102,738   1,877,983   100,000     5.3                
          3/31/89  1,511,400    453,123    1,058,277   100,000     9.4                
          Total $15,633,203    $5,826,043  $9,807,160  $899,444    9.2%               


               Petitioner's annual sales increased from $26,254,806 in                
          fiscal year 1982 to $42,493,252 in fiscal year 1987, $43,627,256            
          in fiscal year 1988, and $42,978,226 in fiscal year 1989.                   






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