Mary T. King and Fatai O. King - Page 16




                                        - 16 -                                          
             thereof, petitioners introduced 13 checks payable to “Bell                 
             of Pennsylvania”.  Respondent notes that five of those                     
             checks, in the aggregate amount of $426.23, bear notations                 
             to show that they were paid with respect to a telephone                    
             number assigned to petitioners’ newsstand at Germantown                    
             Avenue.  Respondent appears to concede that those checks                   
             are deductible.  Respondent also notes that six of the                     
             checks, in the aggregate amount of $762.58, bear notations                 
             which suggest that they were paid with respect to a                        
             telephone number assigned to the newsstand at Broad and                    
             Oxford Streets.  Petitioner initially testified that that                  
             newsstand was closed during the entire year.  He then                      
             changed his testimony to say that the newsstand at Broad                   
             and Oxford Streets was open on the weekends when inspectors                
             from the Department of Licenses and Inspections were not                   
             working.  We agree with respondent that petitioner’s vague                 
             and contradictory testimony does not substantiate those                    
             checks.  Similarly, two checks in the aggregate amount of                  
             $189 bear no notation and we agree with respondent that                    
             petitioners have not substantiated those checks.                           
             Accordingly, we agree with respondent that petitioner is                   
             entitled to a deduction for utilities in the aggregate                     
             amount of $826.68, $400.45 for payments to PECO for                        








Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  Next

Last modified: May 25, 2011