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1993 tax years, petitioner claimed several different bases in
Special Occasions for the years in issue. At trial, petitioner
contended her bases in Special Occasions for the 1992 and 1993
tax years were $5,4098 and $5,429,9 respectively. After trial,
petitioner contended her bases in Special Occasions for the 1992
and 1993 tax years were $3,28310 and $3,010,11 respectively.
To support her contentions, petitioner submitted a computer-
generated list of amounts petitioner purportedly borrowed from
her credit card accounts and contributed to Special Occasions.
Petitioner's list also included expenses incurred on behalf of
Special Occasions drawn from petitioner's personal checking
account.
We do not find petitioner's list to be credible, and we
therefore do not accept petitioner's calculations. Petitioner's
list is not based on any written business records kept by Special
Occasions and is not complete. Additionally, the record
8 This amount was computed using claimed purchases in the
amount of $1,806.96 and claimed auto expenses in the amount of
$3,602.05.
9 This amount was computed using claimed purchases in the
amount of $1,505.84 and claimed auto expenses in the amount of
$3,922.54.
10 This amount was computed using claimed purchases in the
amount of $2,022.97 and claimed auto expenses in the amount of
$1,260.40.
11 This amount was computed using claimed purchases in the
amount of $1,636.93 and claimed auto expenses in the amount of
$1,372.89.
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