- 14 - record to substantiate petitioner’s claim that Dormer & Louver’s 1995 gross receipts were overstated. Moreover, petitioner did not testify or offer any other evidence as to the cost of goods sold. Thus, we are unable to estimate with a degree of reliability the amount of Dormer & Louver’s cost of goods sold for 1995. Because of petitioner’s inexactitude, we sustain respondent on this issue. B. Schedule C Business Expense Deductions for 1993, 1994, and 1995 1. Rent Expenses Petitioners claimed rent expenses of $20,510 for 1993, $20,510 for 1994, and $41,637 for 1995. With respect to the rent expenses of $20,510 for 1993 and $20,510 for 1994, petitioner testified that he believed these figures were accurate. Petitioner’s testimony was not sufficient to enable us to estimate the rent expenses. Indeed, petitioner did not even testify as to whether rent was actually paid, nor did he identify the lessor, the amount of rent, or the rental period. Morever, petitioner disputed the claimed $41,637 rent expense for 1995 and in general, testified that the 1995 return was “blown out of proportion.” Again, because petitioner presented no evidence, documentary or otherwise, to substantiate the rent expenses, we sustain respondent’s determinations on this issue. 2. Supplies Petitioners claimed Schedule C expenses for supplies in the amounts of $112,413 for 1993, $131,014 for 1994, and $5,203 forPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011