- 24 - 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 fromPage: 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