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produced seven canceled checks to Lorraine S. Whipps, each in the
amount of $50. The dates of these checks indicated that they
were issued approximately every 2 weeks from September 14 to
December 14, 1990. The records of the Registry record these
checks as "Contract Wages", and petitioner testified that they
were paid for miscellaneous labor for the business. We hold that
petitioners have established that these items were deductible
expenses.
With respect to the "other" expenses claimed in the amount
of $20,730, petitioners now apparently claim that $16,755 of this
amount actually represents trust preparation fees, which should
have been claimed on the Schedule C for ENT rather than the
Schedule C for the Registry. Petitioner testified that he
operated ENT and that ENT did "business consulting, living trust,
and also was involved in starting a couple of other businesses; a
legal preparation services business and some others." The checks
making up the $16,755 were all drawn on ENT's account.
Petitioner gave no explanation of how checks drawn on ENT's
account were deducted as expenses of the Registry, nor is it
clear whether or not these amounts were already deducted on ENT's
Schedule C. There was no other documentation (such as invoices
or contracts) presented showing the nature and purpose of these
payments. Petitioners again simply failed to prove entitlement
to the deductions claimed.
Petitioners appear to argue that the remainder of the
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