Charles Shaw - Page 14

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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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