- 30 - Respondent did not explain the basis or standard used to determine whether a given item would be included in the purchases for which a deduction was allowed in 1991 or 1992. The agent did not attempt to account for beginning and ending year inventories. It appears to the Court, however, that the agent, having confirmed that the goods acquired for the buyers group were distributed to the members at cost, allowed a deduction for items identified as purchases made for the buyers group. Consistent with that determination, we shall allow a deduction for purchases made for the buyers group. Additionally, we shall allow a deduction for payments unrelated to the buyers group but attributable to sales or transactions completed during the taxable year at issue. 1. Klein News Klein News is a distributor of magazines. In 1990, Raymond agreed to provide metal racks to hold plastic pages, sleeves, and hard plastic for sports cards for Klein News. Klein News agreed to purchase between $20,000 and $25,000 worth of merchandise per month. On December 26, 1990, Raymond wrote a check in the amount of $24,048.85 made payable to Ohio Coin for payment of merchandise bought from Ohio Coin related to the deal with Klein News. In 1991, Raymond sold merchandise to Klein News for $23,987.46, the payment for which was deposited into the Ameritrust account on February 1, 1991.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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