- 2 - After concessions, the only issue remaining for decision is whether petitioners are entitled to a bad debt deduction for 1990 in the amount of $30,500. Some of the facts have been stipulated, and the stipulated facts are incorporated herein by this reference. At the time the petition was filed, petitioners resided in Kirkland, Washington. Richard Soo Kim (petitioner) owned a business that operated as a subcontractor for various garment manufacturers. Petitioner's employees would sew and press the garments before they were packed and returned to the manufacturers. Petitioner contends that garments in his possession, which belonged to certain manufacturers, were stolen by one of his employees. In order to repay the manufacturers for the missing garments, petitioner reduced the amount of future invoices to the manufacturers by the value of the garments. Petitioner deducted the amount of the invoice reductions on Schedule C, Profit or Loss From Business, attached to petitioners' 1990 Form 1040, U.S.,Individual Income Tax Return. Petitioners' apparent position is that, because subsequent invoices were reduced, the business did not receive certain income from services the business performed for the manufacturers. This reduction, petitioners allege, is a business bad debt. Petitioners bear the burden of proving that they are entitled to any claimed deduction. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). This includesPage: Previous 1 2 3 4 5 6 Next
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