- 21 - Respondent argues that petitioner's exhibit does not support its contention as to its taxable years 1991 through 1993. Additionally, respondent argues that petitioner provides conflicting facts; viz, petitioner's Dun & Bradstreet report: (1) States that, as of September 9, 1992, petitioner's bank was NationsBank of Georgia, NA, but that, as of October 9, 1993, petitioner's bank was Trust Company of Georgia, and (2) lists petitioner's account averages as "moderate 5 figures." We agree with respondent and hold that petitioner has not disclosed in its statement a sufficient basis to justify its accumulation for the purpose of maintaining favorable banking relations. Accordingly, we hold that the burden of proof remains with petitioner as to the fifth ground. 6. Maintenance of Favorable Supplier Relationships Petitioner states that it reasonably accumulated $10 million during each of the years in issue to maintain a 4-A credit rating with Dun & Bradstreet. Petitioner states that, during the years in issue, petitioner's management "made a determination to continuously strive for a 4-A credit rating" from Dun & Bradstreet, which requires a net worth of at least $10 million. Additionally, petitioner states that the accumulation of capital has enabled petitioner to maintain a 4-A credit rating for the past several years, which it views as a distinct advantage in an industry known for slow paying manufacturers and retailers.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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