Danielle L. Clark-Hernandez - Page 26




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          wholesale suppliers were allowed while those from retail                    
          merchants, e.g., Target and Walgreens, were disallowed.                     
               While we accept petitioner’s testimony that she purchased              
          supplies at retail establishments for convenience, it is unclear            
          whether petitioner excluded personal items contemporaneously                
          purchased with business supplies and materials.  After review of            
          the record, it is evident that petitioner could not substantiate            
          the amount of expenses which respondent allowed for the years in            
          issue.  It is petitioner’s burden to present evidence to the                
          Court proving the necessity of each item in the ordinary course             
          of business.  The Court again finds that petitioner’s receipts              
          are in such a disarray that the amounts respondent had previously           
          allowed were not discernable.  Based upon the above, we find that           
          petitioner is not entitled to deductions or cost of goods sold in           
          excess of those which respondent has allowed.                               
          G.  Section 6651(a)                                                         
               Respondent determined additions to tax as a result of                  
          petitioner’s failure to file timely returns for 1991 and 1992.              
          Section 6651(a)(1) imposes an addition to tax for failure to                
          timely file a tax return.  The addition to tax is equal to 5                
          percent of the amount of the tax required to be shown on the                
          return if the failure to file is not for more than 1 month.  See            
          sec. 6651(a)(1).  An additional 5 percent is imposed for each               
          month or fraction thereof in which the failure to file continues,           






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