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Peoplefeeders' Expenses
Peoplefeeders' Cash ReceiptsAnd Loan Payments Paid
Taxable Transferred Into IntercompanyOut Of Intercompany
Year Bank Account Bank Account Difference
1988 $ 782,266 $1,449,289 $ 667,023
1989 690,964 1,454,344 763,380
1990 902,115 1,530,067 627,952
1991 1,053,523 1,490,889 437,366
1992 927,586 2,183,805 1,256,219
Total $4,356,454 $8,108,394 $3,751,940
Books and Records
The record herein does not adequately reflect how, at the
time cash sales receipts were received by the various
restaurants, the cash receipts were recorded, if at all, on the
books and records of Peoplefeeders, of Square Pan, and of the
other related corporate entities. The evidence does not indicate
that, at the time cash receipts were received by the restaurants,
debit entries were made to a cash bookkeeping account, nor that
credit entries were made to a sales account.
The record, however, does establish that when cash receipts
were transferred from the separate bank accounts of the
restaurants into the Intercompany bank account, entries were
made, apparently for the first time, in the books and records of
Peoplefeeders, of Square Pan, and of the other corporate
subsidiaries. Again, however, the parties’ briefs and the
limited portions of petitioner's books and records that were
introduced into evidence herein are confusing, incomplete, and
unclear as to specifically how the transfers of cash into, and
the payment of expenses out of, the Intercompany bank account
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Last modified: May 25, 2011