Kern S. and Soledad D. Smith - Page 4

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          writing and exchanged by the parties at least 15 days before the            
          first day of the trial session.”  No such documents were shown to           
          respondent within the allotted time, and the Court ruled that               
          they were inadmissible at trial.  Nevertheless, in the interest             
          of fairness respondent’s agent did consider petitioners'                    
          documents and conceded deductions totaling $114,394, as follows:            
          Schedule C                 On 1040X        Allowed                          
          Advertising                $4,271          $5,579                           
          Car and truck              12,972           9,040                           
          Depreciation                1,088               0                           
          Insurance                     283             283                           
          Legal & prof.               3,441           3,441                           
          Office exp.                 1,244           1,244                           
          Other business prop.        5,750               0                           
          Supplies                    5,736           3,625                           
          Taxes and license             835             835                           
          Meals & ent.                   91              91                           
          Utilities                     811             811                           
          Answering service           1,890               0                           
          Bank charges                  224             224                           
          Consulting                  1,500           1,500                           
          Demos/training                 81              81                           
          Dues/pubs.                     75              75                           
          Equinox                    16,009               0                           
          Management fees             5,970               0                           
          Misc.                         310             310                           
          Newspaper                  10,813               0                           
          Postage                       471             471                           
          Printing                      781             781                           
          Sales promotion             1,011           1,011                           
          Telephone                   6,292           6,477                           
          Carriers                   96,687          78,515                           
          Totals                $178,636        $114,394                              



               Respondent's determinations in the statutory notice of                 
          deficiency are presumed correct, and petitioners bear the burden            




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Last modified: May 25, 2011