Raymond F. Kling and Barbara K. Kling - Page 47




                                       - 47 -                                         
          part of the bulk purchasing for the buyers group.  Petitioners              
          have failed to establish that the cost of the pinball machine is            
          deductible in 1992.                                                         
          7.  Dishonored Checks                                                       
               Of the $58,971 respondent allowed for purchases in 1992,               
          checks totaling $18,130 were dishonored due to insufficient                 
          funds.  Petitioners concede that, in computing the amount of                
          income for 1992, the amount of purchases allowed by respondent              
          for 1992 should be reduced by $18,130.                                      
          8.  Star Account Miscellaneous Expenses                                     
               Respondent reduced gross receipts for 1991 and 1992 for all            
          miscellaneous charges made against the Ameritrust account.                  
          Respondent did not reduce the gross income to reflect the $885.86           
          miscellaneous expenses from the Star Bank account.  Star Bank is            
          the successor to Ameritrust.  The Star Bank account is the same             
          account as the Ameritrust account.  We see no reason why the                
          charges should be treated differently.  We find, therefore, the             
          gross receipts for 1992 should be reduced by $885.86.                       
          F.  Conclusion                                                              
               Rounding the amounts above to the nearest dollar, we find              
          that petitioners are entitled to deduct additional purchases of             
          $52,680 in 1991 and $10,313 in 1992 computed as follows:                    










Page:  Previous  37  38  39  40  41  42  43  44  45  46  47  48  49  50  51  52  53  54  55  56  Next

Last modified: May 25, 2011