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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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