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than respondent determined for that year. Respondent does not
meet this burden by pointing out gaps in petitioner’s proof. In
calculating petitioner’s costs of goods sold, respondent did not
account for any payments 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 1993-95,
despite the fact that these are companies with which Far Eastern
did business during the years in issue. Williams did not obtain
canceled checks from petitioner’s bank accounts for the years in
issue because they were numerous and he thought that his
supervisor would not approve the cost of copying them. This
suggests that respondent did not count all of petitioner’s costs
in calculating petitioner’s costs of goods sold. Respondent’s
apparent failure to account for payments to some of the companies
with which Far Eastern did business and respondent’s failure to
obtain petitioner’s checks casts doubt on respondent’s contention
that petitioner’s costs of goods sold is less than respondent
determined.
Respondent has not shown that petitioner’s costs of goods
sold were less than respondent determined.
e. Conclusion
We conclude that, because neither party has proven
otherwise, petitioner had costs of goods sold as respondent
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