- 12 - 1989 and $167,669 for the year 1990.4 Actually the notice of deficiency listed all of the deduction categories, including the labor and materials (purchases) items described on the returns as cost of goods sold, simply as Schedule C expenses. For 1989 respondent reduced purchases from $10,760 to $8,420 and reduced subcontract labor from $8,853 to $7,706. For 1990 respondent increased cost of labor from $53,300 to $67,388 and reduced materials and supplies from $73,239 to $34,344. Of the 13 categories of Schedule C expenses (not including depreciation) reported in 1989, respondent reduced the allowable expenses in six categories by a total of $7,514 and increased four categories by a total of $4,185, for a net reduction of $3,329. Of the 18 categories of Schedule C expenses (not including depreciation) for 1990, respondent decreased eight categories by a total of $52,557 and increased six categories by a total of $28,704, for a net reduction of $23,853. Respondent also identified $3,063 of personal expenses for insurance and 4 The Court does not read this as a stipulation that Mr. Womack's property services business in fact involved cost of goods sold. See Velinsky v. Commissioner, T.C. Memo. 1996-180, where on the facts of that case the Court concluded that there was indeed cost of goods sold. On the record in the present case, the Court concludes that the income of the business is derived from performance of services, principally lawn care services. The record does not indicate that Mr. Womack maintained any inventories or sold goods to customers or clients. To the extent that the stipulation can be read as showing that this case involves cost of goods sold, the Court will disregard the stipulation as a legal conclusion unsupported by the factual record.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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