Prudential Overall Supply - Page 12




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          Petitioner used this method for purposes of preparing its Federal           
          income tax returns for 1968 through the years in issue.                     
               Respondent conducted audits of petitioner’s Federal income             
          tax returns for 1971, 1972, 1974, 1975, 1991, and 1992, and no              
          change or adjustment was made with respect to petitioner’s method           
          of deducting the cost of garments and dust control items when               
          placed in service.  During the audit for the years in issue, an             
          employee of petitioner stated to the auditing agent, in the words           
          of the auditing agent:                                                      
               they didn’t want any contract to be less than five                     
               years, because the cost of these garments was so much,                 
               and the materials lasted so long that they–-and they                   
               were all made to specific order, that if you stopped                   
               your contract, they had nothing-–they had nowhere to                   
               put these uniforms, because it was made to each client.                
               * * *                                                                  
          Another employee stated to the auditing agent that, “with just a            
          little repair”, some of the mats could last more than 10 years.             
          Notices of Deficiency                                                       
               In the notices of deficiency, respondent “determined that              
          * * * [petitioner] used an unallowable method to value * * *                
          inventory and to compute * * * Cost of Goods Sold”.  The                    
          deficiency amounts calculated by respondent reflected a                     
          determination that the industrial garments had a useful life of             
          between 2 and 4 years and were 3-year class property; the clean             
          room garments had a useful life of between 4 and 10 years and               
          were 5-year class property; the dust control items, other than              






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