- 14 - 1995. Petitioner contends that he had costs of goods sold of $568,937.79 in 1993, $504,199.79 in 1994, and $560,235.41 in 1995. Petitioner bears the burden of proving that his costs of goods sold for 1993-95 were greater than respondent determined. Rule 142(a)(1). Respondent contends that petitioner had costs of goods sold of $74,012 for 1993, $201,963 for 1994, and $101,395 for 1995. Respondent bears the burden of proving that costs of goods sold are less than respondent determined. Id. b. Whether Documents Bearing the Names Shanghai Charles, Shanghai Shen, and Jindge Zhen Are Admissible Petitioner offered what appears to be summaries on company invoice forms bearing the names of Shanghai Charles (Exhibit 79- P), Shanghai Shen (Exhibit 80-P), and Jindge Zhen (Exhibit 81-P) to show the amounts he paid to those companies in 1993-95. Exhibits 79-P and 80-P are dated “Jane 7 2001” (sic). Exhibit 81-P is not dated. Exhibits 79-P and 81-P are stamped with a company seal but not signed. Exhibit 80-P is signed by an unidentified person but not stamped with a company seal. The summaries state that petitioner paid the following amounts for merchandise: Merchant 1993 1994 1995 Shanghai Charles $194,000 $181,500 $149,000 Shanghai Shen 115,000 94,500 103,500 Jindge Zhen 174,500 131,600 154,400 Total 483,500 407,600 406,900Page: 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