- 3 - Petitioner signed a lease for retail space in the mall in August 1994, and paid a rent deposit of $3,750. During 1994, petitioner paid $15,964.41 for cabinets, shelving, and a cash register--all of which he intended to use in the store. During 1994, petitioner purchased $56,217.79 in inventory (model trains and related items). Most of the inventory petitioner purchased were items manufacturers advertised heavily in the fall of 1994, in the hope of selling them in November and December of that year. Manufacturers did not advertise those items after 1994; they then began advertising items which they hoped to sell during 1995. In 1994, petitioner spent $1,226.80 for advertising, $106.05 for commissions and fees, $731.80 in interest, $3,750 in advance rent, $417.74 for supplies, $72 for taxes and licenses, $83.63 for utilities, and $92.45 for books and publications. Unusually heavy rains from September through December 1994 delayed the opening of the mall until April 1995. The commercial space which petitioner planned to lease was not available for occupancy during 1994. In April 1995, petitioner began occupying the commercial space in the mall. Petitioner sold a few inventory items to acquaintances and family during 1994. From November 1994 through April 1995, petitioner stored all of the remaining inventory in his home. OPINION Respondent disallowed petitioners' claim for cost of goods sold on Schedule C on the ground that petitioner did not sell orPage: Previous 1 2 3 4 5 Next
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