- 23 - categories to report labor expenses. For 1991, respondent disallowed a claimed deduction for wages of $600 and allowed petitioner’s claimed payroll expense deduction of $1,015 and cost of labor, as a cost of goods sold, of $8,838 in full. As to years 1992 and 1993, respondent allowed, in full, claimed deductions for wages of $4,583 and $2,085, respectively. In addition to allowing petitioner’s claimed payroll deductions for years 1992 and 1993, respondent credited petitioner an additional $9 and $27, respectively. Respondent, however, disallowed $169 of petitioner’s claimed cost of labor, as a cost of goods sold, for 1992. For 1993, respondent disallowed $62 of petitioner’s claimed outside services expense deduction. Reasonable compensation for services actually rendered is deductible under section 162 as an ordinary and necessary business expense. See sec. 162(a)(1). It is unclear why petitioner separated payments made to employees into four separate categories; nevertheless, we discuss them together as they clearly refer to payments petitioner made as compensation for services rendered. It is respondent’s position that petitioner has duplicated her 1991 wages expense in amounts previously allowed by respondent under payroll and cost of labor. Petitioner offered the testimony of Ms. Sigrist and Ms. Comeau to prove that thePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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