Virginia Ferguson, f.k.a. Virginia Del Bosque, and Estate of Armand J. Del Bosque, Deceased, Lori Del Bosque, Special Administrator, et al. - Page 25

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               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.                                             







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