- 27 - general ledger showed the sale of Petroleum's propane inventory by Petroleum, with Products as agent, to unrelated third parties in bulk sales. Petroleum's handling of its propane inventory was consistent with industry practice. As agent for Petroleum, Products collected from third party purchasers payments due to Petroleum, and it was responsible for pursuing any unpaid propane bills. If, however, a bill remained unpaid, it was Petroleum, not Products, that had to bear the loss. For the taxable years in issue, Petroleum, Products, and Texgas had the following volumes and values of propane production: Parties Propane Sales Propane Sales 1983 Volume (gallons) Value Old Petroleum 8,521,279 $3,918,477 Products 290,982,398 142,699,588 Texgas 152,234,737 131,469,955 1984 Old Petroleum 5,349,081 1$2,307,907 Products 351,855,506 161,166,870 Texgas 159,090,931 136,352,438 1985 New Petroleum 7,930,188 $2,994,311 Products 289,494,801 116,275,633 Texgas 151,400,579 124,263,589 1 Petitioners concede that due to an accounting error, the $2,307,907 amount shown as Old Petroleum's propane sales for 1984, although reflected in Petroleum's books, does not include gross receipts received by Old Petroleum from its sales of 818,708 gallons of propane in December 1984. The highest price per gallon of propane during 1984 was approximately 58 cents. Thus, Old Petroleum's gross receipts from its December 1984 propane sales would have been no more that approximately $475,000, resulting in annual gross receipts of no more than $2,782,907 for that year. For 1983, 1984, and 1985, respectively, Products sold 155,614,505, 156,887,148, and 155,225,544 gallons of propane to Texgas. Given that Products was able to obtain all the propanePage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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