Samuel T. Seawright and Carol A. Seawright - Page 7




                                        - 7 -                                         
                         Amount claimed                                               
           Expense item      on return       Amount allowed    Adjustment             
          Car & truck           –-             $467           $(467)                  
          Depreciation        –-             856            (856)                     
          Employee benefit                                                            
          program        $1,106              –-                  1,106                
          Insurance      844                      –-             844                  
          Office expenses     514                 154       361                       
          Other rent     2,781               -–                  2,781                
          Supplies            2,450               –-             2,450                
          Taxes &                                                                     
          licenses       1,776               1,024               751                  
          Mortgage            879               879              –                    
          Utilities          646                404              242                  
          Totals         $10,996             $3,784              $7,212               

               Respondent also disallowed petitioners’ claimed cost of                
          goods sold in its entirety on the grounds that petitioners had              
          failed to substantiate the amount of purchases and had failed to            
          establish the value of Columbia’s opening and closing inventories           
          for taxable year 1995.  Respondent made no adjustment to the                
          amount of Columbia’s 1995 gross receipts as reported by                     
          petitioners.                                                                
               On February 15, 2000, petitioners filed their petition with            
          this Court.  On March 27, 2000, respondent filed his answer,                
          requesting that his determination as set forth in the notice of             
          deficiency be in all respects approved.  On October 2, 2000, the            
          trial was held in Columbia, South Carolina.                                 











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