Zinovy Brodsky - Page 35




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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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