- 8 - Respondent concedes that Allied's income in 1989 should be reduced by $1,700 to reflect loans to employees that were repaid during 1989. Allied's argument is that all of the loans to employees were repaid in the year that the loans were made and, thus, that Allied's income should be reduced by the total amount of the loans to employees in 1988 and 1989. Allied's cash receipts and disbursements journals for 1988 and 1989 were introduced as evidence. None of the deposits were either identified as loan repayments or traceable to particular loans. Except for the $1,700 that was conceded by respondent, no indication is given in the journals that any other loans to employees were repaid during 1988 or 1989. Petitioner's general and uncorroborated testimony is not sufficient to prove that Allied's loans to employees were in fact repaid during the same year that they were made, and the December dates of some loans suggest otherwise. Respondent's determination regarding adjustments to Allied's income, as modified by her concession, will be sustained. Allied also contends that respondent's determination of Allied's expenses for the operation of petitioner's airplanes should be increased by $2,000 and $14,675 in 1988 and 1989, respectively. Respondent argues that Allied is not entitled to additional airplane expenses. For 1988 and 1989, Allied argues that it is entitled to additional depreciation deductions related to petitioner'sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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