J.J. Zand - Page 19

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                     VIII.  Claimed Schedule C Expense Deductions                     
               For the years 1973 through 1981 respondent disallowed                  
          claimed expense deductions in the deficiency notices because (1)            
          they had not been substantiated, (2) they were not shown to be              
          ordinary and necessary, or (3) they were not shown to be the                
          expenses of petitioner, but were those of another taxpayer.24               
                           A.  Cost of Goods Sold for 1973                            
               For the year 1973 petitioner had purchase debits                       
          (expenditures) in the total amount of $100,966.70, computed as              
          follows:                                                                    
                                             Purchase Debits                          
               Company                       (Expenditures)                           
               Portec-Pioneer                $22,029.00                               
               Kuehnennagel                  766.23                                   
               Hobart Brothers               5,134.94                                 
               Hobart Brothers               36.38                                    
               Hobart Brothers               1,006.53                                 
               Intersoll Rand, SA            6,930.00                                 
               F. Khalatbari                 15,233.00                                
               Atlantic Richfield            10,058.62                                
               Galion                        39,772.00                                
               Total purchase debits        $100,966.70                               

               For the year 1973 petitioner's purchase credits                        
          (reimbursements of purchase expenditures) were in the total                 
          amount of $122,888.07, computed as follows:                                 



          24        Certain adjustments have been resolved by the parties and can be  
          reflected in the Rule 155 computations.                                     






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