- 17 - At trial, little evidence was presented with regard to these claimed expenses. With regard, however, to the $106,801 claimed for 1985, there was admitted into evidence at trial an exhibit that does appear to substantiate $21,222 in trucking expenses incurred in 1985 by L & L Supply, which amount we allow. The burden of proof with regard to petitioners' entitlement to these claimed expenses is on petitioners. Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933). Petitioners have provided no basis for further estimating the operating and trucking expenses of L & L Supply. With the exception noted of $21,222 in trucking expenses for 1985, we deny petitioners' claim to additional operating and trucking expenses with regard to L & L Supply. With regard to claimed additional inventory or cost-of- goods-sold expenses of L & L Supply, petitioners, on brief, concede the figures respondent used each year for beginning and ending inventory of L & L Supply. At trial, petitioners offered exhibit 26 as to 1986 purchases and exhibits 6 and 24 as to 1987 purchases of L & L Supply. Information, however, in those exhibits is suspect. For example, in exhibit 26 a claimed payment of $22,779 for an inventory item appears actually to be a payment to an attorney. In exhibits 6 and 24, certain claimed payments for inventory items are represented by cashier's checks that show petitioners as payees. Petitioners claim that since many suppliers would only deal with them in cash, by cashing thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011