Gustafson's Dairy, Inc. - Page 29

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          needs for fiscal year 1987.  The minutes for petitioner's March             
          31, 1988, board meeting included a Bardahl calculation for the              
          first time.  The minutes of the March 31, 1989, meeting also                
          included a Bardahl calculation.  Petitioner based its Bardahl               
          calculations on its prior year's expenses because petitioner had            
          not closed its books by the time of the year-end meetings and               
          operating expenses for the current year were not available.                 
               Based on its operating expenses for the year ending March              
          31, 1987, petitioner concluded that it needed $3,200,000 for                
          working capital for fiscal year 1988.  For fiscal year 1989,                
          petitioner concluded that it needed $3,600,000 for working                  
          capital.                                                                    
               7.   Petitioner's Business Practices                                   
               E.S. Gustafson regularly gave about $30,000 of his own money           
          as Christmas gifts to petitioner's employees.  Neither he nor               
          petitioner deducted these gifts.  E.S. Gustafson made Christmas             
          gifts to the employees for about 15 years, including the years in           
          issue.                                                                      
               Petitioner did not lend money to or own stock in its                   
          suppliers during the years at issue.  Petitioner's officers and             
          directors do not serve as officers or directors of any of its               
          suppliers.                                                                  
               Petitioner did not lend money to its shareholders or invest            
          in unrelated businesses or ventures during the years in issue.              
          Petitioner does not own any airplanes, yachts, condominiums, or             




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