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APPENDIX
Summary of Conceded, Deemed Conceded, Computational,
and Settled Issues
The following is a summary of issues and/or adjustments
conceded, deemed conceded, of a computational nature, or settled.
I. Docket No. 19027-98, Eddie Cordes, Inc.:
A. 1992:
1. Respondent disallowed petitioner’s deduction for a
net operating loss carryback of $22,453 from 1995.
In accordance with certain of respondent’s
concessions for the 1995 taxable year and for
purposes of the Rule 155 computation, respondent
concedes petitioner incurred a net operating loss
in 1995 in the amount of $48,872 and that it may
be properly carried back to 1992.
2. Respondent determined petitioner was liable for an
accuracy-related penalty pursuant to sec. 6662(a).
Respondent concedes that determination.
B. 1994:
1. Respondent increased petitioner’s taxable income
by $61,435 to account for overstated costs of
goods sold. Petitioner concedes this adjustment.
2. Respondent concedes that petitioner’s taxable
income should be decreased by $31,763, pursuant to
sec. 263A, to reflect additional costs of goods
sold.
3. Respondent increased petitioner’s taxable income
by $405,724 to account for receipt of certain
payments from Mr. Cordes. Respondent made an
identical adjustment in docket No. 5508-99, in
order to protect the Government’s interest.
Respondent concedes this adjustment in docket No.
19027-98.
4. Respondent concedes petitioner may be entitled to
deduct a larger amount for charitable
contributions for the taxable year, as and to the
extent shown in the Rule 155 computation.
C. 1995:
1. Respondent increased petitioner’s taxable income
by $83,602 to account for overstated costs of
goods sold. Petitioner concedes this adjustment.
2. Respondent concedes that petitioner’s taxable
income should be decreased by $31,764, pursuant to
sec. 263A, to reflect additional costs of goods
sold.
3. Respondent increased petitioner’s taxable income
by $211,612 to account for receipt of certain
payments from Mr. Cordes. Respondent made an
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