Danielle L. Clark-Hernandez - Page 25




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          amounts of their compensation were not included under payroll               
          expense or cost of labor.  Respondent argues that the amount                
          shown in the Form 1099 Ms. Sigrist received was already included            
          under cost of labor.  Petitioner offered no evidence to                     
          substantiate the 1992 cost of labor deductions.                             
               Petitioner has the burden to substantiate the claimed labor            
          expenses.  See Rule 142.  She has failed to do so.  Petitioner              
          submitted receipts which do not appear to concern wages, payroll,           
          outside services, or cost of labor categories.  The few receipts            
          submitted do not approach the amounts claimed on petitioner’s               
          returns and only add to the confusion.  Contrary to petitioner’s            
          argument, the witnesses at trial could not corroborate who worked           
          on which project and whether the respective witness ever received           
          payment for services rendered.                                              
               Respondent is sustained on this issue.                                 
               2.  Cleaning Supplies/Materials and Supplies (Cost of Goods            
          Sold)                                                                       
               Respondent disallowed deductions for cleaning supplies                 
          expenses of $949 and $3,978 for 1991 and 1993, respectively.                
          Respondent further disallowed materials and supplies, as a cost             
          of goods sold, of $1,516 and $2,875 for 1991 and 1992,                      
          respectively.  Respondent contends that petitioner claimed                  
          amounts for personal items in addition to business supplies.                
          Petitioner contends that only expenses for cleaning supplies from           






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