Efrain J. and Josefina Xuncax - Page 9




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          introduce evidence regarding reasonable cause, substantial                  
          authority, or similar provisions.”  Higbee v. Commissioner, supra           
          at 446.  Rather, “it is the taxpayer’s responsibility to raise              
          those issues.”  Id.  Because, as will be more fully detailed                
          infra, respondent here has introduced sufficient evidence to                
          render the section 6662(a) penalty at least facially applicable,            
          the burden rests on petitioners to show their entitlement to an             
          exception therefrom.                                                        
          II.  Adjustments to Income                                                  
               Computation of the income of a Schedule C business takes               
          into account both cost of goods sold and other business expenses.           
          Cost of goods sold is an offset subtracted from gross receipts in           
          determining gross income.  Sec. 1.61-3(a), Income Tax Regs.                 
          Accordingly, such costs are not treated as deductions and are not           
          subject to the limitations on deductions contained in sections              
          162 and 274.  Metra Chem Corp. v. Commissioner, 88 T.C. 654, 661            
          (1987).  However, any amount claimed as cost of goods sold must             
          be substantiated, and taxpayers are required to maintain records            
          sufficient for this purpose.  Sec. 6001; Newman v. Commissioner,            
          T.C. Memo. 2000-345; Wright v. Commissioner, T.C. Memo. 1993-27;            
          sec. 1.6001-1(a), Income Tax Regs.                                          
               Once the gross income of a business has been calculated,               
          business expense deductions are subtracted in determining net               
          income.  Section 162(a) allows a deduction for “all the ordinary            






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