- 24 - 2. Nondeductible Personal Expenses a. Petitioners’ Leather Goods Purchases In 1987 and 1988, Mr. Jacobsen purchased $3,770 of leather goods for resale each year. Mr. Del Bosque purchased $13,298 of leather goods for resale in 1987, $3,862 for resale in 1988, and $2,375 for resale in 1989. Respondent treated amounts paid by petitioners to North Beach Leathers as nondeductible personal expenses. These were not personal expenditures but rather expenditures for leather goods purchased and resold. Although petitioners did not maintain any records of their purchases, a few receipts were obtained from North Beach Leathers. The receipts show that within a month petitioners purchased numerous jackets in various sizes; the number of jackets purchased supports petitioners’ assertions that the jackets were not for personal use but rather for resale. Petitioners’ leather goods sales activities are further confirmed by the testimony of two individuals to whom petitioners sold leather goods during the years at issue. On the basis of our observation of petitioners’ witnesses at trial, including our observation of their demeanor, we found petitioners’ witnesses to be credible and earnest. Their testimony was direct, plausible, and uncontroverted. It was not evasive, conclusory, or inconsistent. We are satisfied that their testimony was honest.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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