Shigenori Kudo and Motomi Kudo, et al. - Page 72

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               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 bank                   




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