- 72 - Respondent does not challenge the value of the Berkeley restaurant's 1989 beginning inventory. Petitioners contend that Toraya combined the Berkeley restaurant's and the Post Street restaurant's beginning inventories in calculating its gross income for 1989. We have found that the Berkeley restaurant closed in June 1989, and that any usable inventory was transferred to the Post Street restaurant. Toraya would not be entitled to write off any of the Berkeley restaurant's inventory that remained on hand at yearend, because that inventory was not abandoned but was transferred to the Post Street restaurant and was includable in closing inventory for 1989. Toraya, however, would be entitled to claim as part of its cost of goods sold any of the Berkeley restaurant's 1989 beginning inventory that was used or abandoned during 1989. Accordingly, we hold that for 1989, in the Rule 155 computations, in calculating Toraya's cost of goods sold for the year, after taking into account any adjustments to Toraya's cost of goods sold for the year agreed to by the parties or decided by this Court, the Post Street restaurant's closing inventory should be subtracted from the sum of the Post Street and Berkeley restaurants' beginning inventory and the allowable purchases by the Post Street and Berkeley restaurants during 1989. Unreported Income Respondent determined that Toraya had unreported income, consisting of (1) unexplained cash deposits into the bankPage: Previous 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 Next
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