9
from a second ticket agent with check No. 1083 in the amount of
$3,000. We agree, and we find that the $5,500 is allowable as
cost of goods sold.
Petitioner estimated that he purchased tickets for
Ticketline with $3,130 of automatic teller machine (ATM)
withdrawals from the Todge Trust account. The $3,130 of ATM
withdrawals from the Todge Trust account consists of
approximately 17 withdrawals, none of which exceeds $300.
Petitioner has not shown that the $3,130 in ATM withdrawals was
for the purchase of tickets and not for personal expenditures.
Petitioner argues that several items labeled "debit memo" on his
bank statements represent either deductible expenses or cash
withdrawals used for the purchase of tickets. The record does
not support petitioner's argument. Petitioner provided the bank
statements showing the "debit memo" notations. On brief,
petitioner has attempted to explain the "debit memo" items, but
factual representations on brief are not evidence. We sustain
respondent's determination as to these items.
Based on the above findings, we conclude that petitioner has
substantiated cost of goods sold for the Ticketline business in
the amount of $143,004, which consists of $69,700 from the
Ticketline account, $13,300 from the Todge Trust account, $43,250
from the equity credit line, $5,000 from the ULC account, $6,254
of credit card purchases, and $5,500 of purchases directly from
ticket agents.
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