Ghalardi Income Tax Education Foundation - Page 18

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             necessary expenses" incurred during the taxable year in                  
             carrying on their trades or businesses and are deductible                
             under section 162.  Respondent disallowed all the expenses               
             claimed on the Schedules C filed by Ghalardi and                         
             Mr. Webber, as well as the cost of goods sold claimed on                 
             Mr. Webber's Schedule C, because petitioners neither                     
             substantiated any of the amounts claimed nor showed that                 
             the expenses or costs of goods sold were allowable.                      
             Petitioners' contention is frivolous because, at trial,                  
             they introduced no testimony or documents to substantiate                
             any of the expenses or costs of goods sold claimed by                    
             either petitioner.                                                       
                  Second, petitioners assert that the notices of                      
             deficiency issued to them are not reflected in a computer                
             summary of their accounts, designated the "Individual                    
             Master File Tax Module", for 1992 or 1993.  Petitioners                  
             introduced a copy of the computer summary of Mr. Webber's                
             account for 1992 and 1993, but they did not introduce a                  
             computer summary of Ghalardi's account.  Based upon the                  
             computer summary of Mr. Webber's account, petitioners argue              
             "that there has never been an official filing of a notice                
             of deficiency for either year" and that the subject                      
             "Notices of Deficiency are invalid and fraudulent."                      
             Petitioners cite no authority for their contention.                      





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