Knight Furniture Co., Inc. - Page 30




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          a plan is not created simply by adding together the number of               
          sites considered.  See id. at 277.                                          
               Petitioner’s corporate minutes document discussions of the             
          possibility of opening stores in McKinney or Bonham, but no                 
          specific action was taken by the board because the available                
          properties were not suitable.  We realize that not all of the               
          actions and decisions of the board of directors are documented in           
          the corporate minutes, and we have considered the testimony of              
          the corporate officers and petitioner’s realtor.                            
               Based on the facts and circumstances, we agree with                    
          respondent.  Petitioner had an intent to expand its business and            
          seriously investigated the possible expansion into McKinney or              
          Bonham by considering specific properties.  However, no specific,           
          definite, and feasible business expansion plan materialized from            
          the research.  We conclude that petitioner had neither developed            
          a business expansion plan that was definite, specific, and                  
          feasible nor taken a substantial step to implement a business               
          expansion plan.                                                             
               Respondent has met his burden of proof in demonstrating that           
          petitioner did not have a specific, definite, and feasible                  
          business expansion plan during the years in issue and that it was           
          not reasonable for petitioner to accumulate its earnings and                
          profits for this purpose.                                                   








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