- 16 - shows conducted solely by petitioner and from shows conducted outside the former Soviet Union, foreign trade shows held during the taxable year ended July 31, 1996, produced the following net profit: Gross exhibition revenues $20,687,586 Less: Crocus’s direct expenses substantiated 4,003,930 Less: Expocentr lease payments substantiated 7,003,947 Less: Petitioner’s direct expenses 3,563,363 Net Profit 6,116,346 On its Federal income tax returns for the taxable years ended July 31, 1995 and July 31, 1996, petitioner reported as income 25 percent of gross receipts from foreign trade shows held after December 31, 1994, in accordance with the royalty agreement and deducted trade show expenses it incurred directly. Taking into account adjustments to gross receipts agreed to by petitioner and respondent and disregarding receipts from foreign trade shows conducted solely by petitioner and from trade shows conducted outside the former Soviet Union, petitioner reported net income of $922,295 from the stipulated $4,271,229 net profit for foreign trade shows held from December 31, 1994 through July 31, 1995 (25 percent of gross revenues, amounting to $3,267,804, minus petitioner’s direct expenses of $2,345,509) and net income of $1,608,534 from the stipulated $6,116,346 net profit for foreign trade shows held during the fiscal year ended July 31, 1996 (25 percent of gross revenues, amounting to $5,171,897, minus petitioner’s direct expenses of $3,563,363). In so doing,Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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