- 19 -
115 (1933). Petitioner has not established that he paid more for
kitchen remodeling than the $20,000 respondent allowed. He
provided two documents from Frank and Sal Fricano for material
and labor for “tiling kitchen & foyer”.10 Both documents provide
for tiling an area of 305 square feet. The documents could be
estimates rather than invoices, and they do not establish that
the work was completed or that the stated amounts were paid.
Petitioner asserts that he spent several thousand dollars to
add fireplaces to the New Jersey house. He did not provide any
checks or receipts to substantiate the cost of the fireplaces.
We find that petitioner has not established that the capital
improvements he and Mrs. Wood made to the New Jersey house
totaled more than $153,435. We sustain respondent’s
determination on this issue.
III. Net Profits From Petitioner’s Consulting Business
For the years at issue, petitioner reported the following on
the consulting business Schedules C:
1994 1995 1996
Income $75,657 $53,804 $60,072
Expenses (51,879) (27,527) (42,829)
Expense for business use of (6,025) (11,362) (4,674)
Net profit 17,753 14,915 12,569
10One is clearly dated “June 5 - 84”. The second document
is also dated June 5 but it appears the “84” has been changed to
“85”.
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