Hugh G. and Norma J. King - Page 18

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          the amount of gross receipts it shows, and petitioners have not             
          shown that the computerized general ledger is correct.                      
               3.   Conclusion                                                        
               We conclude that petitioners had unreported income and gross           
          receipts in the amounts respondent determined for 1995-97.                  
          C.   Whether Petitioners Are Entitled to Larger Costs of Goods              
               Sold Than Respondent Allowed                                           
               Petitioners contend that respondent incorrectly calculated             
          their costs of goods sold for 1995-98.7  We disagree.                       
               1.   Petitioners’ Opening Inventory for 1995                           
               Petitioners contend that their opening inventory for 1995              
          includes $96,000 that they paid to buy air conditioners in 1994,            
          which they sold in 1995.  We disagree.                                      
               Mrs. King testified that she bought the air conditioners in            
          1994 and sold them in 1995, but she also testified that she did             
          not sell most of them in the year after they were bought.  Mrs.             
          King testified that she discovered the $96,000 omission several             
          months before trial while reviewing records, but petitioners did            
          not offer those records in evidence.  Under these circumstances,            
          it is not clear when petitioners bought or sold the air                     
          conditioners; thus, we are not convinced that the $96,000 is                
          includable in petitioners’ cost of goods sold for 1995.                     

               7  Cost of goods sold is computed by subtracting the value             
          of ending inventory for a year from the sum of opening inventory            
          for and purchases during that year.  See Thor Power Tool Co. v.             
          Commissioner, 439 U.S. 522, 530 n.9 (1979).                                 




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