- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011