Jeffrey C. and Kelly O. Stone - Page 4

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          Expenses               Claimed During Audit1          Allowed               
          Advertising                  $2,508                   $2,324               
          Car & truck                  12,425                   9,822                
          Contract labor                  893                    - 0 -                
          Depreciation                  1,088                    - 0 -                
          Dues & publications           1,199                    273                  
          Interest--Home mortgage        580                     - 0 -                
          Insurance                     3,609                    699                  
          Laundry                       765                      - 0 -                
          Legal & professional          1,539                    155                  
          Meals & entertainment         780                      - 0 -                
          Office expense                1,399                    302                  
          Repairs                       4,207                    38                   
          Sales promotions              983                      - 0 -                
          Security                      754                      - 0 -                
          Supplies                      1,740                    175                  
          Taxes                         1,451                    15                   
          Utilities                     3,850                    2,669                
          Travel                        619                      - 0 -                
          Wages, commissions & fees     2,813                    1,257                
          Bad debt                      - 0 -                    82                   
          Freight                       - 0 -                    150                  
          1  These figures do not necessarily reflect the amounts shown on            
          the 1994 tax returns.  They are taken from the stipulation of               
          facts submitted at the trial.  It is unclear to the Court what              
          concessions, if any, have been made.  Accordingly, the decision             
          will be entered under Rule 155 in order to reflect any                      
          concessions that may have been made.                                        
          Of the $25,025 petitioners claimed during the audit for cost of             
          goods sold, the Montana Department of Revenue and respondent                
          allowed $24,238.                                                            
               The auditing agent disallowed the expenses on the grounds              
          that (1) the expenses were not properly substantiated, (2) the              
          expenses were personal expenses, and (3) the expenses were not              
          business expenses.  Petitioners appealed the Montana Department             
          of Revenues's determination to the State Tax Appeal Board of the            
          State of Montana.  The Board sustained the Department.                      





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