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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011