- 14 -
There remain in issue $7,000 for GAPS and $5,000 for JJM for
the salary/wage category, and $949 for GAPS for the legal/
professional category. Neither GAPS nor JJM produced any
evidence, beyond their 1989 pro forma tax returns, that they
incurred these additional salaries/wages and legal/professional
fees. Petitioners introduced no evidence concerning the nature
and business purpose of the alleged salaries and wages.
Petitioners made no argument in either their opening or reply
brief on either issue. Petitioners have failed to meet their
burden of proof on the additional salaries and wages and the
additional legal and professional fees. Therefore, we uphold
respondent’s determinations on these issues.
Respondent allowed all deductions for corporate supplies,
and the only amounts still at issue in this case are additional
office expenses for GAPS of $1,277, and for JJM of $1,502. In
support of these additional expenses, petitioners proffered
exhibit 102, a purported summary and compilation of receipts
evidencing business expenses. Petitioners claim that exhibit 102
supports these additional deductions. Respondent objected to
exhibit 102 at trial, and renewed her objection on brief, on the
grounds of relevancy, completeness, and hearsay. Although we
reserved ruling on this objection, we find it unnecessary to
rule. Even if exhibit 102 were admitted, it would not establish
the deductibility of the additional office expenses. The first
page of exhibit 102 is a purported summary of the amounts still
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011