- 16 - entities, petitioner and its related entities clearly made up a controlled group of taxpayers for purposes of section 482. Petitioner supplied 95 percent of its related entities' inventory. Petitioner's sales to these entities were therefore "controlled sales" for section 482 purposes. Petitioner booked sales to both related and unrelated entities at the time the merchandise was delivered, debiting its accounts receivable and crediting its sales. The related stores accounted for delivery of this merchandise as a purchase by crediting their accounts payable to petitioner and debiting purchases. All the accounting was performed by petitioner. Petitioner sold merchandise to all it customers (both the related and unrelated stores) at the same price. However, at the end of the year, after petitioner reviewed the financial results of the entire operation of the controlled group, petitioner made rebates only to its related stores. These rebates had the effect of lowering the cost of the merchandise sold to the entities receiving the rebates, which in turn reduced petitioner's income and increased the incomes of the related stores. Petitioner gave preferential rebates totaling $176,548 and $155,000 in fiscal years 1991 and 1992, respectively. Petitioner accounted for these rebates by crediting accounts receivable and debiting sales, thereby eliminating the rebated sales from accrued sales for Federal income tax purposes. For the related entities,Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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