- 12 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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