-9-
and have found those arguments not discussed herein to be
irrelevant and/or without merit.3 Accordingly,
Decision will be entered
for respondent.
3 Although not cited by either party, we also have
considered B.C. Cook & Sons, Inc. v. Commissioner, 59 T.C. 516
(1972). That case is factually distinguishable from the case at
hand. First, in B.C. Cook & Sons, the taxpayer’s inclusion of
the fictitious purchases in its cost of goods sold was erroneous
in that the taxpayer had not made an actual economic outlay for
those purchases. Second, that case involved the claiming of two
deductions for two different items; i.e., (1) the cash for the
embezzlement for which the deduction was claimed and (2) the
fictitious purchases which were erroneously taken into the
computation of costs of goods sold.
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