- 30 - the time. They were oral agreements. [Emphasis supplied.] Furthermore, after petitioner completed his direct testimony regarding returns and allowances, and before discussing the records that he allegedly lost in ship- ping, he stated: "As mentioned earlier, I shipped some information–-I'm done with the returns and allowances at this point." Thus, petitioner again made it clear that the records allegedly lost in shipping did not involve "returns and allowances." Finally, at trial, petitioner stated: "As such, my business logs were in there detailing in the instance of travel and entertainment, who I entertained and what-–and all the other requirements of Section 274(d)." Petitioner did not testify at trial that any of the documents that were allegedly lost involved amounts reported on his returns as "returns and allowances". Moreover, on the basis of the record of this case, we would have difficulty finding that petitioner lost any business records as a result of a shipment from California to petitioner's home in Moorestown, New Jersey. None of the documents introduced by petitioner substantiate a lost shipment of records from California to Moorestown. The documents on which petitioner relies, consisting of twoPage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
Last modified: May 25, 2011