Zeeman Manufacturing Company, Inc. - Page 21

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               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.                 






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