- 4 - 1994,2 by $25,000. He did so to increase petitioners’ income for Social Security purposes. Petitioners understated gross receipts on their Schedule C by $139,993, and purchases by $101,763. Petitioners overstated their fuel tax credit by $8,884 for 1994. OPINION A. Whether Respondent Properly Disallowed Petitioners’ Deduction of $63,630 of Repairs Expenses for 1994 The first issue for decision is whether petitioners may deduct more than $51,203 for repairs expenses for 1994. Petitioners contend that they may deduct $114,823 for repairs expenses for 1994. Petitioners did not report income until they received it, but they deducted some expenses before they paid them. Petitioners contend that this is a proper hybrid method of accounting which they have consistently and properly used to compute and report petitioner’s income and expenses from his logging business. Petitioners also contend that respondent’s determination was an abuse of discretion because the cash method of accounting does not clearly reflect petitioner’s income from the logging business. We disagree. First, petitioners did not explain why the cash method would not clearly reflect their income. Second, petitioners did not use a valid hybrid method of accounting. 2 Petitioner incurred only $114,823 of repair expenses in 1994.Page: Previous 1 2 3 4 5 6 7 8 Next
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