Kenneth Andrew Baratelle - Page 7




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               The parties have agreed that the above checks were issued to           
          the named payees in the amounts stated, and respondent has                  
          conceded that petitioner is entitled to deduct advertising                  
          expenses of $511.                                                           
               Petitioner testified that most of the expenditures were for            
          advertisements, business cards, brochures, and trade                        
          publications.  Petitioner could not recall the purpose of some of           
          the items such as the $20 expenditure to Franklin Photo, the                
          $57.25 expenditure to Landell School, and the multiple                      
          expenditures to the City of Cypress on November 5, 1994.                    
          Petitioner did not introduce as evidence any advertisement,                 
          business cards, or other business items allegedly purchased with            
          the listed checks.                                                          
               Petitioner also claimed a miscellaneous cash amount of $250            
          to cover miscellaneous amounts that he allegedly spent but could            
          not remember or substantiate.  Petitioner conceded at trial that            
          this amount was an estimate.                                                
               On this record, we conclude that respondent’s concession of            
          $511 for advertising is reasonable, and we sustain respondent’s             
          adjustment to petitioner’s advertising expense deduction as                 
          modified.                                                                   
               Car and Truck Expenses                                                 
               On his 1994 Schedule C, petitioner claimed a deduction for             
          car and truck expenses in the amount of $8,840.  In connection              






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