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either event, there is no specific evidence that the suppliers of
sand, gravel, re-bar, anchor bolts and rods, expansion anchors,
holddowns, straps, and piping for sewer and drainage were paid by
a separate check from the developer. To the contrary, sand and
gravel were ordered periodically and delivered to the job site
and used over a period of time. The record also confirms that
re-bar, anchor bolts and rods, expansion anchors, holddowns,
straps, and piping for sewer and drainage were periodically
ordered in bulk and taken as needed from a standing supply that
was maintained in a large metal storage container at petitioner’s
place of business and transported to job sites on a regular
basis. Petitioner did not show the amount of sand and gravel at
job locations as of the end of the taxable period. Nor did
petitioner show the amount of other materials stored in the metal
container or at the job site as of the end of the taxable period.
In addition, petitioner had work in progress (finished concrete
structures) for which components were deducted, but the final
payment may not have been received. Again, petitioner made no
showing of the amount or status of paid-for materials contained
in work in progress at the close of its taxable year.
The majority also attempts to show that the amount of sand
and gravel and other materials on hand at the end of the taxable
year was de minimis by surmising that the percentage cost of
those items reflected in the final product was smaller than the
percentage of labor or concrete. But that in no way shows the
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