Tan Dang and Ke T. Chaw Dang - Page 4




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        of goods sold and gross receipts for Manwah as follows:                       
                            Cost of       Gross                                       
                           Year    goods sold    receipts                             
                          1995    $869,270    $1,088,298                              
                          1996     862,277     1,074,289                              
                          1997     881,352     1,077,288                              
        D.   Audit                                                                    
             Richard Ng, respondent’s revenue agent, audited petitioners’             
        1995, 1996, and 1997 returns.  He went to Manwah and Asian                    
        Services to examine Manwah’s records.  Petitioners gave Ng daily              
        summaries or tapes of Manwah’s sales for 331 days for 1995, 6                 
        months for 1996, 9 months for 1997, and all of 1998.                          
             Ng used three indirect methods to estimate Manwah’s gross                
        receipts for 1995, 1996, and 1997 because petitioners did not have            
        complete daily records of sales for those years.  First, Ng used a            
        percentage markup method.  He applied the following formula to                
        estimate Manwah’s gross receipts:                                             
                  Gross receipts =   Cost of goods sold                               
                  (1 - Profit percentage)                                             
        Ng calculated Manwah’s gross receipts as follows.  He used average            
        gross profit percentages contained in Dun & Bradstreet data for               
        U.S. grocery stores with annual gross receipts of up to $1 million.           
        Those percentages were 22.6 for 1995, 22.5 for 1996, and 21.2 for             
        1997.  He used the costs of goods sold that petitioners reported on           
        their returns for the years in issue.  Using this method, Ng                  








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