- 10 - As a percentage, petitioner estimates the direct costs associated with the various business activities as follows: Business Activity FYE 1995 FYE 1996 FYE 1997 Trees from petitioner’s land 17% 18% 12% Trees from related party land 34 36 31 Trees from unrelated party land 17 18 18 Subtotal 68 73 61 Purchased wood 32 27 39 Total 100 100 100 Financial Accounting The firm of Haverlock, Estey & Curran prepared petitioner’s financial statements for FYE 1995, FYE 1996, and FYE 1997. The financial statements note, in the first footnote, that “The company * * * is on the cash basis of accounting for financial statement and tax reporting. Consequently, accounts payable, receivable and inventory are not recognized in these statements. The estimated figures for each * * * are as follows:” FYE 1995 FYE 1996 FYE 1997 Accounts receivable $1,576,000$3,200,000 $3,500,000 Accounts payable --— --— --- Inventory1 (cost, FIFO) 1,862,8921,477,361 1,862,892 1 The parties agree that if respondent prevails and petitioner is required to maintain inventories, the closing inventory figures are as follows: (1) For FYE 1995, $1,862,892; (2) for FYE 1996, $610,950; and (3) for FYE 1997, $587,334. Income Tax Returns On petitioner’s Forms 1120, U.S. Corporation Income Tax Return, for the years at issue, petitioner listed its business activity as “wood operator” and its product or service as “pulpwood and logs”. Since its inception, and including the years at issue, petitioner has maintained its books and recordsPage: 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