Monty Bisceglia and Patricia Bisceglia - Page 21




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          to the examining agent.  Although their clouded paternity does              
          not inspire confidence that they are correct to the penny, the              
          figures do not seem unreasonable.  Petitioners propose as a                 
          finding of fact that respondent gave them a 10-percent discount             
          on accounts receivable for 1993, 1994, and 1995.  If we accept              
          petitioners’ proposed finding, and if (as it appears) Jack’s                
          figures reflect a 60-percent discount, then for each year in                
          issue respondent’s implied gross receivables figures were less              
          than Jack’s implied gross receivables figures.9  Moreover, our              
          examination of Murphy’s records indicates that many, if not most,           
          of its autos were sold for a modest downpayment (and often a                
          trade-in), with most of the sales price being financed over a               
          period of several months.  It follows that, at the end of any               
          given year, accounts receivable should represent a substantial              
          part of petitioners’ gross sales.  On the Schedules C attached to           
          their tax returns for the years in issue, petitioners reported              
          that Murphy’s had gross receipts of $448,870 for 1993, $371,278             
          for 1994, and $286,532 for 1995.  The yearend accounts receivable           
          figures used by respondent were $171,000, $105,200, and $99,000             


               9 Specifically, if respondent’s net accounts receivable                
          figures reflect a 10-percent discount, the implied gross                    
          receivables figures for yearend 1993, 1994, and 1995 are $190,000           
          ($171,000/.9), $116,889 ($105,200/.9), and $110,000 ($99,000/.9),           
          respectively.  Similarly, if Jack’s net receivables figures                 
          reflect a 60-percent discount, the implied gross receivables                
          figures for these same periods are $251,445 ($100,578/.4),                  
          $194,998 ($77,999/.4), and $119,700 ($47,880/.4), respectively.             





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