4 FY 1992 FY 1993 FY 1994 Gross receipts $2,839,130 $2,905,192 $2,822,943 Compensation of 165,223 272,000 269,000 officers Salaries and wages 1,086,926 991,749 1,018,735 Repairs 26,605 26,459 15,651 Rents 59,338 32,807 33,336 Taxes 152,664 139,273 137,015 Interest 5,179 2,605 3,286 Contributions 4,325 7,745 9,591 Depreciation 75,988 63,943 54,550 Pensions, profit- 172,804 88,663 sharing plans Other deductions1 995,464 976,003 1,050,076 Unappropriated 1,149,031 1,230,404 1,197,598 retained earnings 1 Petitioner's other deductions included expenses for subcontractors, materials and supplies, equipment rental, chemical analysis, waste disposal, trucks, insurance, travel, office, legal and accounting services, permits, telephone, and utilities. Petitioner paid no dividends and had no inventory in fiscal years 1992, 1993, and 1994. C. The Audit and Respondent's Determination In 1995, respondent audited petitioner's 1992, 1993, and 1994 fiscal years (FY). The record does not indicate who respondent talked to or what documents respondent saw during the audit. On May 15, 1996, respondent notified petitioner, pursuant to section 534(b), that respondent intended to issue a notice of deficiency determining that petitioner is liable for the accumulated earnings tax under section 531 for FY 1992, 1993, and 1994. Petitioner had 60 days to file a section 534(c) statement. Sec. 534(c); sec. 1.534-2(d)(2), Income Tax Regs. On June 13,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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