Clyde E. Owens and Marie W. Owens - Page 22

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          Feltrinelli paid a $5,000 franchise fee to the Owens in 1989 or             
          1990.                                                                       
                    c.   Payments for The Owens' Children's College                   
                         Education                                                    
               Mr. and Mrs. Owens contend that they may deduct $8,200 in              
          1989 and $8,100 in 1990 that they gave to their children to go to           
          college.  Mr. and Mrs. Owens testified generally that their                 
          children worked as needed for their businesses.  Mr. and Mrs.               
          Owens did not keep records of this work.  We conclude that Mr.              
          and Mrs. Owens may not deduct these amounts.                                
                    d.   Other Claimed Deductions and Cost of Goods Sold              
               There is no evidence to support petitioners' contentions               
          that they may deduct more than respondent allowed for charitable            
          contributions, wages for part-time help, utilities, insurance,              
          interest and taxes, a tractor, a low boy trailer, a tanker truck,           
          and car and truck expenses, or that their cost of goods sold was            
          more than respondent allowed.  Mrs. Owens testified that she lost           
          some of the truck expense and car deduction records for the years           
          in issue, but petitioners did not offer enough other evidence to            
          show that they may deduct these items.  Respondent conceded that            
          petitioners may deduct some items based on statements by                    
          petitioners.  For example, respondent concedes that petitioners             
          may deduct some payments for utilities, goods and supplies, and             
          employees' wages.                                                           







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