Ronald F. and Linda C. Bernard - Page 3

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               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 or            



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