William and Shirley Pratt - Page 14




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          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 for             





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