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11 checks made out to banks and credit card companies in
the aggregate amount of $4,166.31. According to notations
on the checks, the expenditures were to purchase racks,
safes, air conditioners, and other equipment. However, the
notations were written in different ink and petitioners
introduced no invoices. Petitioner’s testimony was vague
and inconsistent. In sum, we are not satisfied that
petitioners have substantiated the nature of the
expenditures claimed.
Petitioners claim a deduction of $1,362 for taxes and
licenses. In support thereof, they introduced copies of
15 checks totaling $1,052.90. Respondent conceded $890.90
of these expenditures at trial and conceded an additional
$40 on brief for a total of $930.90. The following is a
list of the checks that shows which checks have been
agreed by respondent and which checks were not agreed:
Not
Check No. Payee Claimed Agreed Agreed
1707 Dept. of Revenue City of Phila.$200.00 $200.00 --
1706 Dept. of Revenue City of Phila.200.00 200.00 --
1695 Dept. of L&I 80.00 80.00 –
1680 Dept. of L&I 40.00 40.00 --
1681 Dept. of L&I 40.00 40.00 –
1682 Dept. of L&I 40.00 40.00 –
1694 Dept. of L&I 80.00 80.00 –
1315 City of Phila. 40.00 40.00 –
1357 City of Phila. 15.00 -- $15.00
1665 Pa. Revenue Dept. 27.00 -- 27.00
1635 Pa. Lottery 15.00 15.00 –
1748 Pa. Revenue 75.00 75.00 –
1747 Pa. Revenue 68.90 68.90 –
1705 Dept. of State 52.00 52.00 –
1709 Dept. of State 80.00 -– 80.00
1,052.90 930.90 122.00
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