- 11 - revenue, cost of sales, operating expenses, and net income after taxes as follows:3 1996 1997 Sales Revenue $22,041,000 $24,600,452 Cost of Sales 6,567,000 8,352,577 Operating Expenses 8,577,000 8,658,527 Net Income After Taxes 6,027,000 4,202,672 For 1996 and 1997, the respective yearend financial balance sheets of petitioner, of Holdings LLC, of Operating LLC, and of ADCS-Limited reflected cash assets as follows: 1996 1997 Petitioner $ 16,549 $ 7,876 Holdings LLC 12,582 11,623 Operating LLC 9,974 8,880 ADCS-Limited 3,545,495 5,212,451 Prior to the years in issue, ADCS had retained, and not distributed to its individual shareholders, a cumulative total of $9.7 million in earnings. During petitioner’s 1996 and 1997 short taxable years in issue, ADCS-Limited retained approximately $1.9 million and $2.9 million, respectively, in current earnings, and petitioner did not distribute any retained earnings to shareholders. Petitioner, however, did make distributions on behalf of its 3 The figures for 1996 for sales revenue, cost of sales, operating expenses, and net income after taxes do not include figures for ADCS-Korea as such figures were not included in the record. The figures for 1997 reflect the figures for all of petitioner’s affiliated companies and for ADCS-Korea.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011