- 11 - petitioner may avoid interest and grow from within, solid banking and supplier relationships, and controlled expansion and improvement in a risky business. Petitioner does not borrow money and has not done so since 1965. Petitioner's policy is to finance current and future needs from within. In its statement, petitioner asserts that it has not permitted its earnings and profits to accumulate beyond the reasonable needs of its business. Petitioner argues, to the contrary, that its accumulated earnings and profits are inadequate to meet its future business requirements. Petitioner states that it reasonably accumulated $23,002,264 in taxable year 1991, $23,257,978 in taxable year 1992, and $24,218,583 in taxable year 1993. We address individually each of the ten grounds asserted by petitioner as reasonable business needs. Respondent has made no concessions as to any grounds. 1. Working Capital Needs In its statement, petitioner sets forth working capital needs of its business as a ground that it reasonably accumulated $7,418,264 in taxable year 1991, $7,673,978 in taxable year 1992, and $8,634,583 in taxable year 1993. Petitioner calculated such needs using the average business cycle method developed in Bardahl Manufacturing Corp. v. Commissioner, T.C. Memo. 1965-200 (the Bardahl formula). Respondent argues that petitioner used an unconventional method of computing the Bardahl formula and that petitioner'sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011