- 22 - 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 orderPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011