Danielle L. Clark-Hernandez - Page 24




                                       - 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 the               






Page:  Previous  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  Next

Last modified: May 25, 2011