17
9012 9112 9212
Per return $1419282 $4147691 $3306595
Per audit 2934384 4145992 3320229
Adjustment $15051021 $ (1699) $ 13634
1 The correct adjustment for 1990 is $1,515,102. Respondent does not
explain this discrepancy.
The copy that respondent sent to petitioner did not disclose
that it differed from the original version. The change makes the
letter appear more likely to be the letter to which the notice of
deficiency refers because the notice of deficiency states that
the letter furnished to the taxpayer was based on an examination
of Eagle's 1990, 1991, and 1992 years.
The Court held a hearing on October 29, 1996, relating to
petitioner's allegation that respondent had provided an altered
document to be included in the stipulation. Respondent's agent
testified that she had not added the 1992 column to the report
and did not know who did. The Court held a second hearing on
October 30, 1996, based on petitioner's allegation that the
revenue agent's testimony was false. At the second hearing,
respondent's agent testified that she had added the 1992 column.
II. OPINION
A. Tax Treatment of Eagle's Customer Deposits
1. Petitioner's Contentions
Petitioner contends that Eagle need not report all of its
customer deposits in the year received. Petitioner contends that
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