- 4 - While petitioner sometimes went to Lee’s office to view the computer chips that Lee had purchased, petitioner never took possession of the chips, did not maintain any inventory or supply of computer chips, did not know the sales price of the computer chips, and did not maintain any records relating to the purchase or sale of the computer chips. The only records petitioner maintained were of the amount of funds that he advanced to Lee and the amount of the return that Lee owed him on those advances. During 1991, petitioner received a return on his advances and commissions from Lee in the amount of $799,550. During 1992, petitioner received a return on his advances from Lee in the amount of $340,152. As of December 31, 1991, Lee owed petitioner expected returns of $250,000 on funds that petitioner had advanced to him. Likewise, as of December 31, 1992, Lee owed petitioner expected returns of $140,000 on funds that petitioner had advanced to him. For the 1991 tax year, petitioners reported $799,550 as gross receipts and $250,000 as costs of goods sold on the Schedule C attached to their tax return. For the 1992 tax year, petitioners reported $340,152 as gross receipts and $140,000 as costs of goods sold on the Schedule C attached to their return. The gross receipts figures shown on petitioners’ 1991 and 1992 Schedules C do not reflect the sales of the computer chips by Lee to third parties. Rather, the gross receipts representPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011