Ward AG Products, Inc. - Page 9

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               Petitioner's costs of sales were $2,752,954.45 for taxable             
          year 1990 (74.83 percent of sales), $3,200,223.61 for taxable               
          year 1991 (86.98 percent of sales), and $3,203,800.05 for taxable           
          year 1992 (81.91 percent of sales).                                         
               Petitioner used the accrual method of accounting on its                
          Florida sales tax returns.  More than 95 percent of petitioner's            
          sales were exempt from Florida sales tax.                                   
          E.   Sale of Petitioner                                                     
               Ward sold petitioner to United Agri Products, Inc. (UAP), on           
          August 18, 1994.  As part of the negotiations, petitioner gave              
          UAP financial statements and documents which showed the amount of           
          petitioner's accounts receivable, accounts payable, and                     
          inventories.                                                                
               W.D. Ward worked for UAP after the sale.  Ward's wife later            
          paid UAP about $70,000 because UAP could not collect some of                
          petitioner's accounts receivable.                                           
          F.   Comparison of Petitioner's Income Under the Cash and Accrual           
               Methods of Accounting                                                  
               Petitioner's taxable income under the cash method of                   
          accounting was $130,390 for 1990, $76,384 for 1991, and ($61,782)           
          for 1992.  Petitioner's taxable income under the accrual method             
          of accounting was $497,288 for 1990, $37,081 for 1991, and                  
          $364,332 for 1992.                                                          








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