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in the account until the October 1997 entry was made,
respondent concluded that the $400,746 was an accumulation of
coupon and buy-down payments received by Nick’s Liquors for the
period of January through October 1997.
Third, petitioner admitted that $73,392 of coupon and buy-
down income from 1996 activity had been reported in 1997.
Further, respondent calculated that $100,810 of coupon and buy-
down income for 1997 activity was reported in 1998. Due to usual
time delays in processing reimbursement payments, respondent
based this figure on petitioner’s reported November and December
1997 coupon and buy-down income.
Lastly, respondent made a downward adjustment of $63,940 to
prevent duplication with respect to rack and promotional income.
Respondent’s calculation, which is on the basis of evidence in
the record of this case, resulted in $895,829 of coupon and buy-
down income for 1997. Respondent’s calculation is summarized as
follows:
Payments received in 1997:
Coupon and buy-down checks used
to acquire cashier’s checks $531,606
Other amounts deposited and
recorded in financial records 400,746
932,352
Adjustments:
1996 income reported in 1997 (73,392)
1997 income reported in 1998 100,810
Rack and promotional income
(duplicate adjustment) (63,940)
1997 coupon and buy-down income 895,830
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