- 29 -
a series of checks totaling $27,175 to Debra for John and Dave's
orders; Raymond also ordered some of the sheets and paid for the
purchase by wire transfer; Jeff, however, did not send the sheets
that John, Dave, and Raymond had ordered; it took Raymond several
months to get the money back; Raymond received cash and some
merchandise from Jeff; as Raymond received the money from Jeff,
he deposited the cash into his Ameritrust account, and then he
sent the money to John and Dave; Raymond sold some of the
merchandise he received from Roth for $4,200 and sent a check to
John for $4,200.
Although petitioners' pretrial memorandum indicates that
they would call John to testify as a witness, petitioners failed
to bring a single witness to corroborate Raymond's story. Thus,
petitioners failed to carry their burden of proving that these
funds represent items that should not be included in their
income.
E. Adjustments for Purchases/Cost of Goods Sold or Expenses
Respondent allowed petitioners a deduction of $353,234 in
1991 and $58,971 in 1992 for purchases or cost of goods sold.
Respondent also allowed a deduction for rental expense of $6,000
in 1991 and $5,000 in 1992 Petitioners claim that the deductions
for purchases and expenses should be increased for additional
amounts.
Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: May 25, 2011