Marian Wilson - Page 14

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          petitioner's name.  Ultimately, petitioner has failed to                    
          establish the reliability of her records.                                   
               Because of the inaccuracy and confusion surrounding the                
          records of petitioner, we adopt respondent's calculations for               
          petitioner's bases in Special O for the years in issue.  This               
          Court finds respondent's calculations to be more credible than              
          petitioner's unsubstantiated assertions.  Again, we find                    
          respondent's calculations to be very generous.                              
               Accordingly, we hold that petitioner is entitled to claim a            
          bases in Special O of $4,966, $3,117, and $6,566 for the 1991,              
          1992, and 1993 tax years, respectively.  Respondent is sustained            
          on this issue.                                                              
          3.  Travel Expenses                                                         
               Petitioner contends that Special O is entitled to claim                
          travel expense deductions in the amount of $740.81, $2,497, and             
          $1,529 for the 1991, 1992, and 1993 tax years, respectively.                
          These amounts represent travel expenses allegedly incurred by               
          petitioner and her sisters on behalf of Special O.  In 1991,                
          petitioner contends that Faye Oatis13 and Linda Klyce traveled to           
          San Diego and Tijuana, Mexico, allegedly to find a cheap fabric             
          supply source.  In 1992, petitioner contends that petitioner,               
          Faye Oatis, and Linda Klyce traveled to Baton Rouge, New Orleans,           

          13   Faye Oatis was not an employee or shareholder of Special O             
          during the years at issue.                                                  

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