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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.
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