- 5 - for the fiscal year ended May 31, 1995, had been destroyed or misplaced. Having become aware of Ms. Groom’s audit, respondent examined her audit report for the applicable period and adopted it in principal to determine petitioner’s gross sales for the period June 1, 1994, through April 30, 1995. Respondent also relied upon petitioner’s “Statement of Revenues, Expenses and Retained Earnings” for the month ended May 31, 1995. After reviewing Ms. Groom’s audit report and petitioner’s “Statement of Revenues, Expenses and Retained Earnings” for the month ended May 31, 1995, respondent determined that petitioner had gross sales of $1,808,423 for the fiscal year ended May 31, 1995. From that amount, respondent allowed the following deductions: Sales tax $108,318 Other voids 23,085 Voids and overrings 237,342 $368,745 Respondent deducted from the amount of gross sales ($1,808,423) the foregoing amount of $368,745 and calculated an amount of net gross sales of $1,439,678 for the applicable period. The record shows that petitioner does not challenge the amounts determined as deductions for sales tax, other voids, and voids and overrings. On its Federal income tax return for the fiscal year ended May 31, 1995, petitioner reported income of $1,319,308. In his notice of deficiency dated January 3, 2001, respondent determinedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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