Hans C. Sherrer - Page 14




                                        -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