- 122 - 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.Page: Previous 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 Next
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