James H. Shelton, Deceased, and Eve Shelton - Page 5

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          his seminars.3  In arriving at the gross income reported on the                    
          Schedule C, petitioners claimed cost of goods sold in the amount                   
          of $7,030, computed as follows:                                                    
                     Beginning inventory           $ -0-                                     
                     Purchases                      8,949                                    
                     Materials & supplies           1,152                                    
                     Ending inventory               3,071                                    
                     Cost of goods sold             7,030                                    
          Petitioners also deducted various business expenses on the                         
          Schedule C in the total amount of $11,409, resulting in a net                      
          loss of $11,200.                                                                   
                In the notice of deficiency, respondent made the following                   
          adjustments to the items contained on the Schedule C:                              
                                      Amount Per                                             
          Item                        Return          Adjustment       Allowed               
          Cost of Goods sold          $7,030          $7,030           $  -0-                
          Advertising                 1,282           -0-              1,282                 
          Insurance                   1,475           1,475            -0-                   
          Legal/Prof.                100             -0-              100                   
          Office Exp.                 135             -0-              135                   
          Rent                        2,082           2,082            -0-                   
          Repairs & Main.       170                   -0-              170                   
          Taxes & Licenses            279             -0-              279                   
          Travel                      2,053           2,053            -0-                   
          Utilities             745                   -0-              745                   
          Other expenses:                                                                    
          Accounting                  128             -0-              128                   
          Trade dues                  282             -0-              282                   
          Contrs.                     2,187           -0-              2,187                 
          Postage                     491             -0-              491                   

                Respondent explained her adjustment to petitioners' cost of                  
          goods sold as follows: "Since you did not establish that the                       

          3Petitioner's records indicate that there were small amounts                       
          of income identified as "misc." or "interest" included in the                      
          gross receipts reported on the Schedule C.                                         




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