- 9 - amount of those entries was the same as the amount shown on the purported product usage document as the last entry under the column headed “NET TOTAL (IN BOTTLES)”. (We shall refer to the adjusting journal entries prepared by Mr. Miller on the basis of the purported product usage document as the royalty adjusting journal entries.) After having prepared the royalty adjusting journal entries, Mr. Miller completed preparation of petitioner’s Form 1120 for its taxable year ended January 31, 1994, based on those entries and petitioner’s financial statements for the fiscal year ended on the same date. Thereafter, but prior to booking the royalty adjusting journal entries in petitioner’s books and prior to filing petitioner’s return for the year at issue, Mr. Miller confirmed with Mr. Braswell the correctness of booking those entries. When Mr. Miller booked the royalty adjusting journal entries in petitioner’s books, he included an explanation in those entries that he was making them “per AGB”, i.e., per A. Glenn Braswell. Petitioner claimed, inter alia, a royalty expense deduction in the amount of $1,158,084 in the Form 1120 that it filed for the year at issue. In the notice of deficiency (notice) issued to petitioner for the year at issue, respondent determined that petitioner erroneously deducted $1,158,084 as a royalty expense and in- creased petitioner’s income for that year by that amount.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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