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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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