- 6 - Taxable Income Taxable Income Before Rebates After Rebates Fiscal Year 1991 Petitioner $292,000 $116,124 Kapsco (107,987) 12,013 NPC (56,899) 149 Fiscal Year 1992 Petitioner 251,323 96,232 NPC (113,993) 1,009 KAW 13,544 53,544 Petitioner determined the amount of rebates at the end of each fiscal year by giving consideration to its own taxable income as well as that of the related entities. The rebates were based neither on volume discounts petitioner received from its suppliers nor on the volume of sales petitioner made to the related entities. Indeed, petitioner sold approximately the same quantity of merchandise to its related entities each year. Further, there is nothing in the record to suggest that the rebates were tied to any benefits that petitioner received from the related stores. The Related Stores' Financial Condition a. Kapsco Kapsco's fiscal year 1991 financial statements (which included the financial results of 9-10 individual retail stores) reflected total shareholders' equity of $419,322 and retained earnings of $274,868. In that year, Kapsco received from petitioner $120,000 in rebates. (Had there been no rebates in fiscal year 1991, Kapsco's total shareholders' equity would have been $299,322 and retained earnings would have been $154,868.)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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