- 3 - time late in 1992 or early in 1993, Mr. Juarez left petitioner’s employ, and he became associated with her again in approximately March 1993. When Mr. Juarez became reassociated with petitioner, they entered into an arrangement under which Mr. Juarez would act as some form of intermediary between petitioner and the customer or consumer of the manufactured piecework. Mr. Juarez operated under this arrangement beginning around March 22, 1993, using the name “Lemarant Fashion’s”. The documents offered by petitioner in an attempt to show that this type of arrangement existed in 1992, had been falsified by changing the year from 1993 to 1992. ULTIMATE FINDING OF FACT Petitioner failed to show that she is entitled to deduct any part of the $459,650 that she claimed as commissions and fees, which were disallowed by respondent. OPINION This case presents a clearly defined factual question. Respondent disallowed $459,650 that petitioner had claimed as commissions and fees on her 1992 Schedule C. Petitioner, in support of her position that she is entitled to deduct the questioned amount, testified that Mr. Juarez was paid the amount as an intermediary between herself and the customer. Petitioner also offered a purchase order book reflecting 1992 transactions with Mr. Juarez.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011