- 56 - (e) For 1989, petitioner documented salary payments of $22,288.21 (Ex. 40-R, lines 509-532) and daycare expenses of $1,591.80 paid for one of her employees (Ex. 40-R, lines 551- 571), the deductibility of which respondent has conceded. (f) For 1990, petitioner documented salary payments of $6,658.20 (Ex. 41-R, lines 98-116) and $18,707.32 (Ex. 41-R, lines 856-873), the deductibility of which respondent has conceded. Although petitioner did not introduce all of her payroll records into evidence, we are convinced that her failure to do so was more likely than not the result of the sheer volume of documentation with which she was dealing at trial and the lack of attention paid by both petitioner and respondent to the actual Schedule C categories. Petitioner, however, credibly testified at trial that she paid salaries, a telephone allowance, life insurance, health insurance, school and summer childcare expenses, and automobile expenses (including car insurance, a gas allowance, and car payments) to or for the benefit of her employees during 1987, 1988, and part of 1989. We also note that the documented amounts if annualized would generate an annual figure consistent with, or larger than, the amounts claimed on petitioner’s Schedules C for the years at issue. We shall apply the Cohan rule to uphold petitioner’s wage and employee benefits deductions for each of the years at issue.Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
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