- 13 - and the written statement is both ambiguous and so blatantly conjectural as to be almost useless for estimation purposes. The document states that EJX “approximately paid 15 to 20 employees in cash” and that “The amount that this employees received yearly was approximately ten thousands dollars.” Hence, at minimum it is unclear whether 15 to 20 employees received $10,000 each or whether 15 to 20 employees received $10,000 in the aggregate. If the former, we are doubtful of the statement’s veracity. Wages and labor costs, both as reported on the 1996 return and as substantiated, total less than $60,000. It thus seems highly unlikely that additional employee payments of $150,000 to $200,000 were made through less conventional channels and were mistakenly omitted from petitioners’ return. On the other hand, if the latter interpretation should hold sway, we note that respondent’s generosity already allows for a deduction of more than $20,000 beyond the substantiated amount. Thus, under any interpretation, petitioners’ assertions fall short of showing their entitlement to further wages expense deductions. C. Rent Rent expense of $31,200 was claimed on petitioners’ Schedule C. The information provided to respondent on this item consisted of rental receipts for the 1995, rather than the 1996, taxable year. The invoice for December of 1995 shows monthly rent of $1,750. Respondent allowed rent expense for 1996 at a rate ofPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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