Zeeman Manufacturing Company, Inc. - Page 22

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               Petitioner states that, because of its credit rating, it               
          receives numerous merchandise and fabric offers on favorable                
          credit terms.  Petitioner also states that it saves several                 
          hundred thousand dollars as a result of discounts on its                    
          purchases.  Petitioner names several suppliers that have given              
          petitioner favorable credit terms because of petitioner's credit            
          rating.  Petitioner states that, because of its credit rating, it           
          is approached by suppliers several times per month with excess              
          merchandise at reduced prices.  Additionally, petitioner states             
          that real estate agents contact petitioner with business                    
          opportunities and cites an instance when, during 1993, petitioner           
          was contacted by the owner of some real estate.                             
               Respondent argues that the specifics concerning the                    
          "favorable relationships" are not set forth.  Respondent argues             
          that petitioner did not indicate a monetary amount that was saved           
          because of its credit rating.  Respondent also argues that                  
          petitioner did not present any attempts by management to quantify           
          the impact of obtaining and maintaining a 4-A credit rating.                
          Additionally, respondent argues that the Dun & Bradstreet report            
          that was attached to petitioner's statement presents conflicting            
          information.                                                                
               We agree with respondent.  Accordingly, we hold that                   
          petitioner has not disclosed in its statement sufficient details            
          to justify petitioner's asserted management decision to                     
          accumulate $10 million during its taxable years in issue in order           




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