- 29 - Petitioner's income taxes for fiscal years 1991 and 1992 were substantially understated as a result of (1) giving rebates to its related entities for which it has shown no economic justification other than to avoid taxation, and (2) writing down its ending inventory in the respective amounts of $160,000 and $415,000 in fiscal years 1991 and 1992. Our discussion in Issue 1 leaves no doubt that petitioner had no reasonable basis or substantial authority for its position of giving the rebates. We will hereinafter discuss whether petitioner was justified in writing down its ending inventory. Petitioner maintained a perpetual inventory system. On a daily basis, purchase invoice amounts were plugged into petitioner's computer and sales were taken off on a daily sales sheet, leaving an inventory balance. Each month, if amounts sold were greater than purchases, ending inventory would be lower than the previous month. If amounts sold were less than purchases, ending inventory would be higher than the previous month. At yearend, petitioner relied on its perpetual inventory system and took no physical inventory of goods on hand. As new inventory was purchased, petitioner updated its book inventory cost per unit on the basis of the most recent invoice price from suppliers. Petitioner had no significant amounts of obsolete inventory in stock in the years at issue. If inventory became obsolete, petitioner's suppliers would normally accept the inventory inPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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