Diana Lynn Taub - Page 3

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               Petitioner’s 1989 and 1990 Schedules C report that she has             
          an unincorporated business that provides acting, modeling, and              
          art/design services.  The 1989 Schedule C reports income of $650            
          and cost of goods sold and deductions totaling $13,800; i.e.,               
          cost of goods sold ($6,700), advertising ($1,800), legal and                
          professional services ($1,500), office expense ($2,000), supplies           
          ($1,200), and utilities ($600).  Petitioner’s 1990 Schedule C               
          reports income of $750 and cost of goods sold and deductions                
          totaling $15,200; i.e., cost of goods sold ($4,000), advertising            
          ($2,700), legal and professional services ($2,200), office                  
          expense ($4,500), supplies ($1,200), and utilities ($600).                  
               Respondent disallowed all of the costs of goods sold and               
          deductions reported on petitioner’s 1989 and 1990 Schedules C.              
          In part, respondent determined, petitioner did not prove that any           
          of these amounts were:  (1) Paid or (2) ordinary and necessary              
          business expenses.                                                          
               Petitioner must prove respondent's determination wrong.                
          Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).                  
          Petitioner has not done so.  She has produced no meaningful                 
          evidence rebutting respondent's determination, and the record is            
          devoid of evidence otherwise disproving it.  Petitioner claims              
          she had the documents necessary to disprove respondent’s                    
          determination, but that the documents were either lost by her or            
          destroyed in a hurricane.  We find this argument unpersuasive.              






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