Efrain J. and Josefina Xuncax - Page 13




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          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 of              






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