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          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 propane              
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