- 21 - 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.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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