Nemetschek North America, Inc. - Page 4

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          purposes.  Specifically, Diehl used the:  (1) Cash receipts and             
          disbursements method (cash method) to report its receipts and               
          certain expenditures and (2) lower of cost or market method to              
          value its yearend inventory.  At the beginning and end of its               
          1995 taxable year, Diehl had an inventory valued for Federal                
          income tax purposes at $112,945 and $132,820, respectively.                 
          Diehl’s inventory consisted of:  (1) Blank disks, (2) software,             
          manuals, binders, and videos, and (3) shipping materials and                
          other supplies.  The values of those items on May 31, 1994 and              
          1995, were as follows:                                                      
          May 31, 1994   May 31,                                                      
          1995                                                                        
          Blank disks                               $11,530        $16,156            
          Software, manuals, binders, and videos     85,904        106,353            
          Shipping materials and other supplies      15,513         10,311            
          Total                                   1112,947        132,820             
               1 The $2 difference between this amount and the $122,945 listed        
          immediately above and below is attributable to rounding.                    
               Diehl reported taxable income of $1,603,678 for its 1995               
          taxable year.  It computed and reported its cost of goods sold as           
          follows:                                                                    
                    Inventory at beginning of year   $112,945                         
                    Purchases                         510,898                         
                    Cost of labor                      32,260                         
                    Commissions                         4,961                         
                    Inventory scrap                    17,680                         
                    Total                             678,744                         
                    Inventory at end of year          132,820                         
                    Cost of goods sold                545,924                         
               Respondent determined that Diehl was required to use an                
          overall accrual method to reflect its income clearly.  Respondent           




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