- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011