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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 483,500 407,600 406,900
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