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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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