Herbert C. Haynes, Inc. - Page 10

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          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 records             





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