- 13 - sold (including the calculations therefor), inventories, inventory turnover, sales, accounts receivable, accounts receivable turnover, merchandise purchased, accounts payable, accounts payable turnover, and days in adjusted operating cycle. Accordingly, we conclude that petitioner has made a sufficient disclosure as to the accumulation for working capital needs based upon the Bardahl formula. We believe that respondent's arguments concerning petitioner's particular Bardahl formula and computation, the source of petitioner's financial information in its Bardahl computation, and the discrepancies between petitioner's Bardahl computation and the Dun & Bradstreet credit compilation are arguments to be interposed at trial and need not be addressed in deciding the instant motion. Accordingly, we hold that, for purposes of section 534(c), petitioner has made a sufficient disclosure of the formula and data it relies upon to show its working capital needs. Gustafson's Dairy, Inc. v. Commissioner, supra. Consequently, we hold that respondent bears the burden of proof as to the working capital needs of petitioner's business to the extent of $7,418,264 for taxable year 1991, $7,673,978 for taxable year 1992, and $8,634,583 for taxable year 1993. We note that respondent may carry the burden of proof at trial by establishing, e.g., that the formula itself is unreasonable or the data are inaccurate or unrealistic. Id.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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