- 8 - provided her inventory did not substantially lose its value.5 However, petitioner asserts that at the end of 1994 there was only a balance of $150 in inventory.6 Petitioner made no attempt to substantiate her beginning and ending inventory figures. We do not find petitioner's calculations of cost of goods sold to be reliable, because beginning and ending inventory figures were not supported by evidence. Consequently, petitioner may not reduce her gross receipts by any amount in excess of that determined by respondent in the notices of deficiency. In the notices of deficiency for the taxable years 1993 and 1994, respondent disallowed various expenses related to petitioner's wholesale and consulting activities. Respondent determined that petitioner did not meet her burden of proof that these expenses were actually incurred. 5This can be demonstrated by the following calculation: Beginning inventory 1993 $2,450 Purchases 1993 and 1994 6,313 Amount sold (at cost) (2,000) Ending inventory 1994 $6,763 (projected) This also assumes, though we do not decide, that petitioner's reported amount for beginning inventory was correct. 6At trial, petitioner's accountant testified that items sold by petitioner were all sold to various customers at a price from $2 to $10 greater than her cost for the items. If petitioner did sell the inventory at some level of markup, we note that the ending inventory figure would be higher.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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