Helen Sophie Schroeder - Page 8

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          Petitioner's 1991 Cost of Goods Sold3                                              
                Petitioner reported $4,890 as cost of goods sold on Schedule                 
          F on her 1991 tax return.4  The $4,890 represents the purchase                     
          price of livestock and beef as follows:                                            
                Magic (horse)                    $800                                        
                Pigs (10 at $45 each)            450                                         
                Pigs (20 at $40 each)            800                                         
                Beef (6 at $380 each)            2,280                                       
                Goats (20 at $10 each)           200                                         
                Goats (15 at $15 each)            1360                                       
                Total                            4,890                                       
                1 Petitioner's math was in error.  The correct total should                  
          be $225.                                                                           
          Petitioner bought Magic from Standish Livestock Sales in 1991.                     
          Petitioner did not believe that she bought 35 goats, although she                  
          reported both the purchase and sale of 35 goats on her 1991 tax                    
          return.  Petitioner did not report the sale of any pigs on her                     
          1991 tax return.                                                                   
          Petitioner's 1992 Cost of Goods Sold                                               
                Petitioner calculated her cost of goods sold on part III of                  
          Schedule C on her 1992 tax return as follows:                                      
                Inventory at beginning of year                   $5,850                      
                Purchases                                        -0-                         
                Cost of labor                                    -0-                         

                3  Since respondent does not dispute that the items in                       
          question are allowable as cost of goods sold if properly                           
          substantiated, we will decide only whether adequate                                
          substantiation has been shown.                                                     
                4  Petitioner reported her business activities on Schedule F                 
          in 1991 using the cash method of accounting.  Petitioner changed                   
          the nature of her business and reported it on Schedule C in 1992                   
          and 1993 using the accrual method of accounting.                                   




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