United Parcel Service of America - Page 54




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                         b.   Accounting                                              
               For the taxable years ended December 31, 1983 and 1984, UPS-           
          New York and UPS-Ohio were required to file annual reports with             
          the ICC and were required to follow the rules of accounting and             
          use the accounts established by the ICC in connection with ICC              
          accounting and reporting requirements.  Petitioner was also                 
          required to follow Generally Accepted Accounting Principles.  For           
          financial accounting and managerial reporting purposes,                     
          petitioner used a system of accounts that was generally the same            
          as the ICC system of account numbers.  However, petitioner's                
          expense accounts are much more detailed than ICC expense accounts           
          used for ICC accounting purposes.                                           
               With respect to a shipment made by a regular customer, there           
          was no change in the method in which journal entries were made in           
          1983 and 1984.  Petitioner generally debited accounts receivable            
          and credited an intercompany account.  When petitioner received             
          the EVC amounts from its shippers, the amounts were deposited in            
          petitioner's bank accounts.  Petitioner paid shippers' claims out           
          of corporate bank accounts.                                                 
               Petitioner did make changes to its internal accounting                 
          worksheets at its district level in 1984.  The worksheets                   
          detailed the EVC's differently in 1984 than in 1983.  However,              
          petitioner's accounting journal entries were the same in 1984 as            
          they were in 1983 at the district level.                                    





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