Mountain State Ford Truck Sales, Inc., E.P. O'Meara, Tax Matters Person - Page 10




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               Mountain State Ford generally received invoices on a monthly           
          basis from the manufacturers for the parts that those manufactur-           
          ers had shipped, or had intended to ship, to it.  With respect to           
          those parts, each such invoice showed the part number of each               
          type of part, the quantity of units of each such type, and the              
          purchase price of each such unit.  (We shall sometimes refer to             
          the price of each unit of each type of part as shown on the                 
          invoice that the manufacturer sent to Mountain State Ford as the            
          invoice price.)                                                             
               Upon receipt of a manufacturer's invoice, an employee of               
          Mountain State Ford entered the total of the invoice prices                 
          (aggregate invoice price) of all the parts, but not the invoice             
          price of each unit of each type of part, into an account which              
          Mountain State Ford maintained for the parts that it purchased              
          (purchases account).  Mountain State Ford did not utilize the               
          purchases account in maintaining its inventory.  Another employee           
          of Mountain State Ford in charge of payables verified with the              
          parts department that Mountain State Ford had received the number           
          of units of each type of part that was listed on each invoice,              
          and, if so, Mountain State Ford paid the aggregate invoice price.           
          Once Mountain State Ford paid the aggregate invoice price, it               
          filed the invoice by manufacturer and invoice date.                         
               Where (1) there was a shortage in the quantity of units of             
          one or more types of parts that the manufacturer intended to ship           
          to Mountain State Ford, as shown on the shipping tape and the               
          packing sheets, (2) the manufacturer mistakenly sent Mountain               

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Last modified: May 25, 2011