- 19 -
management decided to accumulate $1 million for that purpose.
Accordingly, we hold that the burden of proof remains with
petitioner as to the third ground.
4. Signage Project
Petitioner states that, during each of its 1992 and 1993
taxable years, it reasonably accumulated $484,000 to cover the
anticipated costs of replacing the signs for stores of its wholly
owned subsidiary Barry Manufacturing Company. Petitioner states
that, during 1993, Barry Zeeman instituted a new corporate logo
requiring new signs to be erected on its 38 different stores.
Petitioner states that it committed to fund the new signage
project and received quotes from various sign companies totaling
approximately $484,000 to complete the project and that its
earnings were earmarked for the cost of the new signs.
Respondent argues that petitioner's statement does not
furnish detailed, clear, and specific information about the
signage project. Respondent argues that petitioner failed to
include the names of the various sign companies contacted and any
quotes or bids from the companies. Additionally, respondent
argues that petitioner did not include facts regarding when the
project was to be completed or an explanation why there was a
delay in completion. Finally, respondent argues that
petitioner's signage project includes 38 stores, which
contradicts petitioner's list of 31 stores elsewhere in the
statement.
Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 NextLast modified: May 25, 2011