Tan Dang and Ke T. Chaw Dang - Page 5




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        estimated Manwah’s gross receipts to be $1,123,087 for 1995,                  
        $1,111,182 for 1996, and $1,118,467 for 1997.                                 
             Second, Ng estimated Manwah’s gross receipts by annualizing              
        the amounts shown on the daily records that petitioners gave him.             
        The record does not include the results of that analysis.                     
             Third, petitioners gave all of Manwah’s records for 1998 to              
        Ng.  Ng used them to estimate the markups of specific products sold           
        in Manwah.  The record does not indicate which products he                    
        analyzed.  Ng concluded that the average markup for those                     
        unspecified products was 25 to 28 percent.                                    
             Respondent determined that petitioners understated Manwah’s              
        gross receipts on their returns solely by applying the Dun &                  
        Bradstreet gross profit percentage data to Manwah’s reported costs            
        of goods sold.  Respondent did not use Ng’s estimate of Manwah’s              
        annualized daily receipts or markup of specific products for 1998             
        to determine petitioners’ unreported income.                                  
                                      OPINION                                         
        A.   Whether Petitioners Underreported Gross Receipts                         
             Petitioners contend that they had gross receipts from Manwah             
        of $1,088,298 for 1995, $1,074,289 for 1996, and $1,077,288 for               
        1997, as they reported on their returns.                                      
             Respondent contends that petitioners had gross receipts of               
        $1,123,087 for 1995, $1,111,182 for 1996, and $1,118,467 for 1997,            








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