T.C. Memo. 2001-261
UNITED STATES TAX COURT
JERRY J. AND SUSAN N. LEBOUEF, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15785-99. Filed October 3, 2001.
R determined a deficiency for Ps’ 1993 taxable
year based primarily on disallowance of: (1) Amounts
claimed for cost of goods sold with respect to a sole
proprietorship and (2) a loss claimed with respect to a
partnership interest.
Held: Ps have failed to overcome their initial
reporting of $244,270 as gross receipts from their sole
proprietorship and, for lack of substantiation, are not
entitled to offset such receipts by an identical amount
for cost of goods sold.
Held, further, Ps are not entitled to deduct a
loss of $19,791 allegedly attributable to their
interest in a partnership.
Held, further, Ps are liable for the sec.
6651(a)(1), I.R.C., addition to tax for failure timely
to file their 1993 income tax return.
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