- 39 - B. Supplies and Services Included among the returns and allowances reported on his 1989 return are payments that petitioner claims to have made to clients to purchase "supplies and services". Petitioner relies upon his own testimony and copies of canceled checks to substantiate this claim. Petitioner testified that the payments in this category, totaling $5,500, consist of payments to three clients, Mr. Dana, Mr. Kolton, and Jepsco, in the amounts of $500, $500, and $4,500, respectively. At trial, petitioner testified that the $500 payment to Mr. Dana was a fee "for supplies that he provided for me in my business", the $4,500 payment to Jepsco was "for consulting fees", and the $500 payment to Mr. Kolton was "for legal services * * * in a probate matter" rendered by Mr. Kolton. Petitioner testified further that Mr. Kolton assisted petitioner with a probate matter and "looked up some stuff and filed a paper". Petitioner introduced copies of three canceled checks payable to Mr. Dana, Mr. Kolton, and Jepsco containing the notations "fee", "serv.", and "consulting", respectively, in the memo section of the checks. The evidence offered by petitioner is insufficient to substantiate that petitioner is entitled to offset gross income by, or to deduct, these amounts. Petitioner'sPage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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