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petitioner’s failure to substantiate (1) the existence and amount
of any contribution, (2) that a contribution was made to a
charitable organization, and (3) that the claimed contribution
was not a prohibited transaction resulting in personal benefit or
inurement. Respondent disallowed petitioner’s claimed exemption
deduction in the amount of $100 because of petitioner’s failure
to show entitlement to such deduction under either section 651 or
652.
Nis Venture Trust
Respondent disallowed petitioner’s cost of goods sold in the
amount of $404,420 and a deduction for Schedule C, Profit or Loss
From Business, expenses in the amount of $9,737 because of
petitioner’s failure to substantiate such expenditures and to
show that such expenses were incurred in a trade or business.
Respondent disallowed an S corporation loss in the amount of
$20,131 because of petitioner’s failure to substantiate such loss
and show that the loss was a business loss. On various grounds,
respondent disallowed an income distribution deduction in the
amount of $1,500, a deduction for attorney’s fees of $1,500, a
deduction for an exemption of $100, and a Schedule E,
Supplemental Income and Loss, expense for rent in the amount of
$1,021.
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Last modified: May 25, 2011