- 25 -
group are correct.
–- The Adjustments
Apparently because the expiration of the period of limitations
on assessment and collection of tax (see sec. 6501), respondent is
limited in the number of years open to adjustment by him. The
earliest year open to an adjustment by respondent is 1998 for
Nissan, Dodge, and Chrysler, and it is 1997 for Volkswagen. For
the earliest and each succeeding year of a member open to
adjustment by him, respondent increased or, in two cases, decreased
the taxable income of the member to reflect respondent’s
recalculation of the member’s beginning and ending inventories for
the year. The amounts of the adjustments in taxable income
resulting from those recalculations, and the taxable years to which
they correspond, are as follows:
Member 1997 1998 1999
Nissan --- $17,251 $41,273
Volkswagen $49,056 35,484 575,137
Dodge --- (37,752) 256,315
Chrysler --- 76,402 (88,687)
Petitioners do not contest those portions of the deficiencies that
result from those adjustments.
In addition, for the earliest year of each member open to
adjustment by respondent (the first year in issue), respondent made
an additional adjustment under section 481. That adjustment
increased the taxable income of the member for that year to reflect
the cumulative adjustments to income revealed by respondent’s
Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 NextLast modified: May 25, 2011