Total Health Center Trust, Bonnie Stejskal, Trustee, et al. - Page 4

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              The adjusting journal entries for the Kansas operation for             
          2000 include the following entry (adjusting journal entry 18):              
          Date                        Acct. No.#    Debit        Credit               
          12/31/00 Inventory            10500               $48,257.92                
                    Product purchases   50000     $48,257.92                          
          Ms. Wilkerson made this entry to adjust the Kansas inventory                
          account in accordance with the actual physical count of ending              
          inventory.  The $48,257.92 is the difference between the trial              
          balance inventory of $171,448.06 and the physical count of                  
          inventory of $123,190.14 and reflects the reduction of inventory            
          caused by the shrinkage, or spoilage, of SET’s products.                    
               On the Schedule C attached to SET’s amended Form 1041, U.S.            
          Income Tax Return for Estates and Trusts, for the 2000 tax year,            
          petitioners reported the following amounts related to cost of               
          goods sold for the Kansas and Texas operations:                             
               Beginning inventory (line 35)      $221,908                            
               Purchases (line 36)                414,832                             
               Ending inventory (line 41)         207,516                             
               Cost of goods sold (line 42)       429,224                             
          The ending inventory amount of $207,516 reported on line 41 of              
          the Schedule C includes a reduction of inventory of $48,257.92              
          caused by shrinkage to the Kansas inventory and accounted for by            
          adjusting journal entry 18.  The product purchases of $414,832              
          reported on line 36 of the Schedule C includes an increase to               






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