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The parties have stipulated that the Forms MQ-79 filed on
behalf of Beaufort Leaf for 1990 report aggregate sales
of flue-cured tobacco of $1,225,535, the amount used by
respondent in computing the partnership's sales.
Similarly, the parties have stipulated that the Forms
MQ-79, filed on behalf of Beaufort Leaf for 1990, report
aggregate sales of burley tobacco of $853,015, the amount
used by respondent in recomputing the partnership's sales.
Thus, the additional income from sales of flue-cured and
burley tobacco computed by respondent for 1990 is based
upon the sales reported in the Forms MQ-79 filed on behalf
of Beaufort Leaf. Respondent determined the amount of
unreported sales from so-called pickens tobacco on the
basis of three receipts which state that Beaufort Leaf
sold pickens tobacco to H.D. Pegram on June 5, 1990, in
the aggregate amount of $74,678.
The attachment referred to in the explanation
accompanying the notices of deficiency also states that
the unreported tobacco sales of Beaufort Leaf for 1991
were recomputed on the basis of "checks written to Beaufort
Leaf Tobacco Company from auction sales of tobacco but not
deposited to the business account" in the aggregate amount
of $1,054,576 and not included in the gross income reported
by the partnership for 1991. The record of this case
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