- 21 -                                         
          determined for the close of each of the years in question the               
          amount of working capital that is reasonably needed to cover a              
          single operating cycle of petitioner.  Petitioner determined the            
          working capital for one operating cycle to be $3,877,503,                   
          $4,090,630, $3,885,163 in 1995, 1996, and 1997, respectively.               
          Respondent determined the working capital for one operating cycle           
          to be $3,735,858, $3,863,008, $3,737,073 in 1995, 1996, and 1997,           
          respectively.  Petitioner used monthly balances to compute the              
          annual average balances of its inventory and accounts receivable,           
          whereas respondent used yearend balances to determine the annual            
          average balances.  We adopt respondent’s calculation because the            
          yearend balances respondent uses have been stipulated by the                
          parties.  The difference in the calculations, however, does not             
          affect the result in this case for the reasons appearing below.             
               2.  Redemption of Stock of Dissenting Minority Stockholders            
               Petitioner contends that there was an actual redemption of             
          stock during the years in issue and a manifest dissent among the            
          Pedigo stockholders.  Petitioner’s officers believed that the               
          action to remove David Pedigo, a large stockholder, as a                    
          corporate officer and reduce his employment responsibilities                
          would strain the relations between the Knight and Pedigo families           
          and could result in the redemption of stock by the Pedigo family.           
               Respondent argues that it was not a reasonably anticipated             
          need of the business to accumulate earnings and profits for the             
          redemption of stock of minority stockholders.  Respondent                   
Page:  Previous   11   12   13   14   15   16   17   18   19   20   21   22   23   24   25   26   27   28   29   30   NextLast modified: May 25, 2011