Ronald F. and Linda C. Bernard - Page 4

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          otherwise dispose of the inventory during 1994, nor did                     
          petitioner offer the inventory for sale to customers in 1994.               
          Respondent also disallowed petitioners' Schedule C deductions               
          claimed for depreciation, rent, and other expenses, on the                  
          grounds that petitioner had not yet begun carrying on a trade or            
          business and that organizational or startup expenses must be                
          capitalized and deducted beginning in the year that the taxpayer            
          begins carrying on the trade or business.                                   
          Cost of Goods Sold                                                          
               The cost of goods purchased for resale, with proper                    
          adjustment for opening and closing inventories, is deductible               
          from gross sales in computing gross income.  Sec. 1.162-1(a),               
          Income Tax Regs.  Cost of goods sold generally is not allowable             
          for goods which have not been sold or otherwise disposed of                 
          during the taxable year.  Jones v. Commissioner, 25 T.C. 1100,              
          1103 (1956), revd. on other grounds 259 F.2d 300 (5th Cir. 1958).           
          Petitioner made no sales to customers during 1994; thus he is not           
          entitled to a deduction for cost of goods sold in that year.2               
               Petitioner contends that the inventory became worthless                
          during 1994.  Although not framed as an inventory accounting                
          issue, it appears that petitioner is essentially contending that            
          he should be allowed to use the lower of cost or market method of           

               2  Petitioner did realize less than $100 from casual sales             
          to friends and acquaintances; however, due to an oversight,                 
          petitioner did not report the income from these sales on his 1994           
          Federal income tax returns.                                                 



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