Scott C. and Patricia A. Simpson - Page 7

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                    THE COURT:  Seems to me it would have been cheaper                
               to go out and buy the videos, than to spend $2,000                     
               renting them.                                                          
                    THE WITNESS:  Well, we ended up going out and                     
               buying them, too, Your Honor.                                          
               In addition to the cost of the 632 meals, petitioners in               
          1993 deducted as supplies $7,000 worth of groceries.  To justify            
          this deduction, Mr. Simpson testified that petitioners provided             
          children in their care with four meals a day.  Mr. Simpson                  
          admitted, however, that his family consumed some of the                     
          groceries.  Furthermore, Mr. Simpson stated that petitioners did            
          not maintain records delineating the groceries that were                    
          exclusively used for the day-care service.  Therefore, even if              
          some of the groceries were attributable to the day-care service,            
          petitioners cannot establish the amount devoted to that purpose.            
          In essence, petitioners want the Government to subsidize their              
          daily food consumption.                                                     
               Petitioners' pattern of deducting personal expenditures was            
          not limited to meals and entertainment.  Petitioners also                   
          deducted supply expenses of $10,994 for 1992 and $16,697 for                
          1993.  These deductions included expenditures for a VCR, a wide-            
          screen television, a satellite television system, and a cross-              
          country ski machine.  Petitioners contend that these expenses               
          were necessary startup costs associated with the day-care                   
          service.  Petitioners have failed, however, to establish a                  







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