Marian Wilson - Page 11




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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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Last modified: May 25, 2011