Anne S. and Charles G. Vick - Page 3

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                         Beginning inventory      $     0                             
                         Purchases                12,000                              
                         Labor                    18,000                              
                         Materials and supplies   4,000                               
                         Other costs              7,500                               
                                                  $41,500                             
                         Ending inventory         (10,850)                            
                         Cost of goods sold       $30,650                             

               In the notice of deficiency, respondent determined that                
          petitioners had unreported income of $3,341 from the corporation            
          and disallowed the entire amount of cost of goods sold for lack             
          of substantiation.                                                          
               The determinations of the Commissioner in a notice of                  
          deficiency are presumed correct, and the taxpayer bears the                 
          burden of showing the determinations are incorrect.  Rule 142(a);           
          Welch v. Helvering, 290 U.S. 111 (1933).                                    
               With respect to the $3,341 received from the corporation,              
          petitioner acknowledged receipt of this amount but contended that           
          the amount represented nontaxable rebates, or purchase-volume               
          discounts, from the corporation.  However, other than his own               
          self-serving testimony, petitioner presented no evidence to                 
          support this contention.  Petitioner failed to meet his burden of           
          proof on this issue.  Accordingly, pursuant to section 61,                  
          petitioners must include this amount in income.  Respondent is              
          sustained on this issue.                                                    







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