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employee who gave Panalpina’s records of petitioner’s imports to
Williams during the audit of petitioner’s 1993-95 tax years was
transferred from New Orleans to Chicago, where she was a manager
or vice president. She was subsequently fired or forced to
resign from Panalpina.
Petitioner gave Williams a document purporting to be a
summary of petitioner’s purchases from Jindge Zhen in 1993-95.
Williams included the amounts from that summary in petitioner’s
costs of good sold for 1993-95. However, Williams did not
include any payments by petitioner to The Hipage Co., Inc.,
Southern Export Services, Bizehen, Shanghai Shen, Boxter Customer
Service, Sam’s Club, Jefferson Variety Store, and Kuang-Yu Wen in
petitioner’s costs of goods sold for 1993-95. Respondent’s
determination of petitioner’s costs of goods sold is based solely
on petitioner’s purchases from Henry’s Gifts and Jindge Zhen and
amounts paid to Panalpina for brokerage services in 1993-95.
Respondent mailed a notice of deficiency to petitioner for
1993-95 on April 11, 2000.
E. Invoice Summaries of Shanghai Charles and Shanghai Shen
In anticipation of the trial in this case, petitioner
obtained documents from one of his brothers in China which
purport to be summaries of petitioner’s purchases in 1993-95 from
Shanghai Charles and Shanghai Shen.
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Last modified: May 25, 2011