Karns Prime & Fancy Food, Ltd. - Page 19

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          the increase in petitioner’s annual purchase requirement under              
          the March 9, 2001 supply agreement second amendment, i.e., an               
          increase of $5 million in required annual product purchases over            
          the $16 million in required annual product purchases set forth in           
          the April 16, 1999 supply agreement before its amendment by the             
          March 9, 2001 supply agreement second amendment.  (We shall refer           
          to such $5 million increase as the $5 million increase in peti-             
          tioner’s annual purchase requirement.)  As a result, petitioner             
          earned under the March 9, 2001 supply agreement second amendment            
          a sales rebate for the annual period ended March 9, 2002, in an             
          amount equal to the annual payment for that period set forth in             
          the March 9, 2001 commercial note, and such rebate offset such              
          annual payment.  For the annual period ended March 9, 2003,                 
          petitioner did not meet the $5 million increase in petitioner’s             
          annual purchase requirement.  As a result, petitioner earned                
          under the March 9, 2001 supply agreement second amendment a sales           
          rebate of $86,573.64 for the annual period ended March 9, 2003,             
          which was $4,929.19 less than the annual payment for that period            
          set forth in the March 9, 2001 commercial note.  Such rebate                
          offset $86,573.64 of such annual payment, and petitioner paid the           
          balance of such annual payment (i.e., $4,929.19).                           
               On June 13, 2000, petitioner, which used the accrual method            
          of accounting, timely filed Form 1120, U.S. Corporation Income              
          Tax Return (petitioner’s return), for its taxable year ended                






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