-14- realized by petitioner during any of the years in issue. We therefore give those estimates little weight. D. Mr. Sager's "Statistical Projections" and Opinion As a check on his estimates of petitioner's income based on the bid sheets, Mr. Sager consulted four books setting forth financial ratios for various industries.2 Mr. Sager stated that according to these sources, plumbing businesses with annual sales of less than $1 million generate net income of approximately 4.2 percent. On the basis of this information--and his personal experience providing accounting services to construction businesses--Mr. Sager expressed the opinion that his estimates of petitioner's income for 1989-92 based on the bid sheets were reasonable. Mr. Sager also opined that the amount of income determined by respondent for each of the years 1990-92 was unreasonable. Mr. Sager testified that in his experience, to come out of a construction job with a 20-percent profit was generally extraordinary. Mr. Sager did admit that respondent's determination of petitioner's business net income for 1989 was reasonable. In addition, part of Mr. Sager's testimony based on his professional experience undercuts both his testimony based on the financial ratios, and his estimates of petitioner's income based on the bid 2 Mr. Sager's report cites Dun & Bradstreet, Industry Norms and Key Business Ratios (1995); Robert Morris Associates, Annual Statement Studies 1995; Schonfeld & Associates, IRS Corporate Financial Ratios (9th ed. 1995); Troy, Almanac of Business and Industrial Financial Ratios (1996).Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011