- 2 - Frederick H. Robinson, Craig D. Miller, Patricia M. Lacey, and Gary R. Vogel, for petitioner. Reid M. Huey, Nancy B. Herbert, Robert J. Kastl, Jennifer H. Decker, James E. Kagy, Timothy S. Sinnott, and Richard G. Goldman, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: Respondent has determined deficiencies in petitioner’s Federal income tax liabilities for the years 1984, 1985, and 1986 in the amounts of $7,152,527, $1,772,936, and $1,668,392, respectively. The parties have reached agreement on certain issues, and the only issue remaining for our consideration is the soundness of certain of petitioner’s accounting systems that allow for the accrual of an estimate of losses from shrinkage factors (e.g., theft and errors in billing) in determining book inventories. Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some facts have been stipulated and are so found. The stipulations of fact filed by the parties and the accompanying exhibits are incorporated herein by this reference. The parties have made approximately 450 separate stipulations of fact,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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