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his personal knowledge of the facts with respect to a particular
transaction or activity about which he testified. We also found
Mr. Raja’s testimony to be vague and/or inconsistent at times.
On the record before us, we find that petitioner has failed
to carry his burden of establishing that, in computing his gross
income from UVW’s business, he is entitled to reduce gross
receipts by the respective amounts of cost of goods sold to which
he claims he is entitled for 1991 and 1992.
Claimed Schedule C Deductions
In the notice for 1991 and 1992, respondent disallowed for
those two years claimed Schedule C deductions of $24,796 and
$16,278, respectively.
Petitioner contends that he is entitled to the following
amounts of Schedule C deductions for interest and telephone
expenses that respondent disallowed in the notice for 1991 and
1992:79
79Petitioner did not raise as an issue in petitioner’s
further trial memorandum, presented no evidence at trial and at
further trial, and makes no argument on brief as to certain
amounts of claimed Schedule C deductions disallowed for 1991 and
1992 that petitioner placed in dispute in the petition and that
respondent has not conceded. We conclude that petitioner has
abandoned contesting those disallowed amounts of claimed Schedule
C expenses. See Rybak v. Commissioner, supra at 566 n.19.
Although petitioner raised as an issue in petitioner’s
further trial memorandum that he is entitled to certain Schedule
C deductions for 1993, petitioner indicates on brief that there
are no Schedule C deductions in dispute for that year.
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