- 10 - accounted for the rebates by debiting their accounts payable and crediting purchases. Petitioner kept track of the aging of receivables from unrelated stores through monthly computer reports. Ralph Dunn, petitioner's office manager, reviewed the accounts receivable aging sheets. Accounts that were not collected were sent to collection agencies. Mr. Dunn prepared the list of petitioner's accounts receivable to be written off by each store and recommended the amount of writeoffs. Petitioner's officers reviewed the list of proposed writeoffs of accounts, which was sent to Mr. Lamprecht at the end of each year. Generally, Mr. Dunn's recommendations were accepted. After petitioner wrote off the delinquent accounts from unrelated entities, petitioner stopped selling merchandise to them. Petitioner did not keep records to reflect the aging of accounts receivable from related stores. Nor did Mr. Dunn recommend writeoffs for any of the related stores. Petitioner's Federal Income Tax Returns On its Federal income tax returns for fiscal years 1991 and 1992, petitioner reported gross sales of $7,628,708.29 and $7,736,795, respectively. Notice of Deficiency In the notice of deficiency, respondent determined that petitioner's gross sales for fiscal years 1991 and 1992 werePage: 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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