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by petitioner during the years in issue. At trial, petitioner
submitted Forms W-2 showing the following:
Year Name Wages, Tips, Other Compensation
1985 Ms. Alshabani $2,405.00
Pam Biedenback 2,450.00
1986 Ms. Alshabani 11,401.00
Manoj Tandon 2,456.04
1987 Ms. Alshabani 13,398.00
Manoj Tandon Illegible
Petitioner submitted checks he wrote to Ms. Alshabani, Pam
Biedenback, and Manoj Tandon which totaled the following:
Year Name Total
1985 Ms. Alshabani $2,095.00
Pam Biedenback 2,080.00
1986 Ms. Alshabani 9,073.00
Manoj Tandon 0.00
1987 Ms. Alshabani 10,875.54
Manoj Tandon 0.00
The checks do not support the amounts the Forms W-2 list as
paid by petitioner as wages. Furthermore, there is no evidence
suggesting in what capacity Pam Biedenback worked for petitioner,
and petitioner did not even testify that he employed her. We
find that petitioner has substantiated that he paid Ms. Alshabani
wages in the amounts of $2,095, $9,073, and $10,875.54 in 1985,
1986, and 1987, respectively. Petitioner has not shown that he
is entitled to wage expense deductions in amounts greater than
those allowed by respondent; therefore, we sustain respondent's
determination on this issue.
2. Leasing Expenses
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