- 49 - transaction with Mr. M., and respondent’s determination is not sustained.14 Respondent determined that petitioner had unreported income of $110 in 1989 from the sale of tickets and tapes to an individual named Paul H. In September of 1989, Paul H. wrote a check to Real Services in the amount of $110, in payment for prerecorded music tapes. Petitioner deposited this check into Real Services’ checking account. Respondent concedes that petitioner is entitled to a cost-of-goods-sold allowance of $12 with respect to these tapes. We accordingly find that petitioner had unreported income of $98 in 1989 from this transaction and sustain respondent’s determination to that extent. B. 1990 Sales of Electronics and Rental Income Respondent determined that petitioner had unreported income of $3,000 in 1990 from the sale of additional electronic equipment to Ted and Brian P. Brian P. confirmed this amount at trial. From numerous receipts, petitioner has identified the items that she purchased and resold to Ted and Brian P. The receipts indicate that her cost for this electronic equipment 14 Petitioner claims an additional $250 exclusion from income, relying upon documentary evidence that she paid that amount for tickets to the Broadway show “M. Butterfly”. The case of Mr. M. indicates, however, that petitioner charged her customers what she paid for Broadway tickets. There is no basis to assume otherwise in the case of the tickets for “M. Butterfly”. Absent some proof to the contrary, we believe that petitioner received full payment for those tickets, offsetting the amount she used to buy them. There is thus no taxable event.Page: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
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