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computation contains mathematical errors. Respondent also
contends that petitioner did not provide the source of the
financial information included in the Bardahl computation.
Alternatively, respondent argues that, as certain amounts in
petitioner's Bardahl computation do not correspond with the
numbers in the Dun & Bradstreet credit compilation attached to
the section 534(c) statement, petitioner's "conflicting"
information does not provide "specific amounts" needed to be
expended for business needs.
In Gustafson's Dairy, Inc. v. Commissioner, T.C. Memo. 1995-
11, we stated that a taxpayer will have made a sufficient
disclosure of its Bardahl computation if the taxpayer adequately
states the formula relied upon for determining an anticipated
need, sufficient data to use the formula, and the end result of
the formula. In its section 534(c) statement, petitioner has
stated a formula, furnished the data to use the formula,5 and
calculated an end result of the formula for its taxable years
ended 1991 through 1993.6 For the Bardahl computation for each
taxable year, petitioner provided, inter alia, the cost of goods
5 We note that, since the filing of the instant motion and the
supporting memoranda of law thereunder, the parties have agreed
to certain changes in the Bardahl computation. We, however,
address only the sec. 534(c) statement and the Bardahl
computation included therein. Sec. 534(a)(2); sec. 1.534-
2(a)(2), Income Tax Regs.
6 Respondent cites no specific mathematical errors, and we
find no such errors in petitioner's Bardahl computation.
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