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Docket No. Year Deficiency
20220-98 1993 $524,103
20221-98 1993 545,324
After concessions,2 the issues for our consideration are:
(1) Whether A.J. Concrete Services, Inc. (AJCS), is entitled to
deduct $2,261,555 in expenses; (2) whether AJCS overreported its
income by $2,680,500; (3) whether AJCS is entitled to a $269,815
deduction for accrued workmen’s compensation expense. Unless
otherwise indicated, all section references are to the Internal
Revenue Code in effect for the periods under consideration, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT3
Petitioners Jeffrey and Genedine Guerrero resided at 4215
Osprey Pointe, Woodstock, Georgia, on the date their petition was
filed. Petitioners Alan and Kathleen Bone resided at 617 North
Lake Drive, Canton, Georgia, at the time their petition was
filed.
2 Respondent concedes that A.J. Concrete Services, Inc.
(AJCS), is entitled to $444,766 in 1993 for costs of goods sold.
This represents the depreciation that AJCS claimed on concrete
forming devices.
3 The parties’ stipulation of facts is incorporated by this
reference. We also incorporate by this reference our findings of
fact in A.J. Concrete Pumping, Inc. v. Commissioner, T.C. Memo.
2001-42, and Guerrero v. Commissioner, T.C. Memo. 2001-44.
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