- 25 - 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,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