Shigenori Kudo and Motomi Kudo, et al. - Page 78

                                       - 78 -                                         
              Moreover, in calculating the markup taking into account                
          respondent's increase in gross receipts, Shimmon accepted as                
          accurate the reductions to purchases expense determined by                  
          respondent on audit.  Following concessions by the parties and              
          our decision relating to that issue, see supra, Shimmon's figures           
          are no longer accurate.  Rather, after taking into consideration            
          the adjustments to the unreported income and cost of goods sold             
          determined by respondent as discussed supra, the restaurants'               
          markups for the years in issue fall below the 225-percent top               
          range used by Shimmon.18  Consequently, the adjusted purchases              

               18  Using totals for the two restaurants owned by Toraya and           
          the one restaurant owned by the Takaos, the adjusted markups are            
          computed as follows:                                                        
          1988         1989        1990        1991                                   
          Gross                                                                       
          receipts                                                                    
          per                                                                         
          return       $1,286,571    $997,067    $810,958    $740,860                 
          Unreported                                                                  
          income           90,900      78,675      35,400       7,800                 
          Adjusted                                                                    
          gross                                                                       
          receipts      1,377,471   1,075,742     846,358     748,660                 
          Cost of                                                                     
          goods sold                                                                  
          per return      467,757     357,634     279,183     249,129                 
          Adjustment to                                                               
          purchases        (3,000)     (3,100)      6,000        --                   
          Adjusted cost                                                               
          of goods sold   464,757     354,534     285,183     249,129                 
                                                             (continued...)           




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