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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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