- 25 - We concluded that, in computing petitioners’ taxable income each year, the cost of the leather goods purchased each year should be deducted from petitioners’ gross receipts as cost of goods sold. b. Mr. Jacobsen’s Clothing Purchases Mr. Jacobsen claims that he often paid for clothing for the limousine drivers. Specifically, he claims that he paid $349 in 1987 to Jerry Leonard, a big and tall men’s store, $349 in 1987 and $771 in 1988 to Daytons department store, and $1,950 in 1988 to Merles department store. Respondent treated these items as Mr. Jacobsen’s personal expenses in computing his income. Mr. Jacobsen did not call any of the limousine drivers to confirm that he made such purchases. He offered no sales receipts or other documentary evidence. We conclude that the items were properly treated as nondeductible personal expenses. c. Mr. Jacobsen’s Purchase of a Mobile Telephone System In 1987, Top Play purchased a mobile telephone system for $1,797. Payment for the system was charged to Mr. Jacobsen’s credit card. Top Play paid the credit card company $1,300 in 1987 and $763 in 1988 for the purchase of the mobile telephone system. Agent Fisher treated this purchase as a nondeductible personal expenditure. Respondent concedes that the item is not a nondeductible personal expense.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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