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With respect to the Schedule C deduction for cost of goods
sold, petitioner presented no documentary evidence to support the
claimed amount and testified he believed all of his records had
been stolen. When questioned by the Court as to the possibility
of documenting the claimed expenditures through other sources,
such as records of purchases from the corporation, petitioner
stated that he had been unable to obtain such evidence. Other
than his own self-serving statements, petitioner presented no
evidence to substantiate the disallowed deduction for cost of
goods sold. Therefore, on this record, respondent's
determination on the disallowance of the Schedule C deduction for
cost of goods sold is sustained.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011