- 68 - Sari Collection,13 and various payments were made to the company throughout the taxable year. However, as shown in a handwritten notation on an invoice from Arizona Natural Resources and in Mayor’s general ledger, petitioners paid only a portion of a billed charged and accrued the remaining $123,250 as an additional account payable as of December 31, 1998. Petitioners mention the purchases adjustment in their pretrial memorandum, stating: “This is a timing issue. The dispute was denied and the $123,250 was paid to Arizona Natural resources [sic], plus interest and attorney fees. Petitioners should not be required to go back and amend returns for a year in which the amount was actually paid.” Petitioners do not discuss the matter on opening brief, while respondent concedes that petitioners did incur valid business expenses with respect to the Sari cosmetic line but argues: “Because there was a dispute over this amount [the $123,250], it was never paid. If it were to have been paid, however, deduction would not be permissible until the date of payment.” Petitioners respond on reply brief, with their argument, in its entirety, consisting again of two sentences: “The monies owed Arizona Natural Resources were paid, but after 1998, and thus, for a period closed for the companies. Thus, the amount should be deducted for 1998.” 13 Petitioners from time to time diversified the products offered through their multilevel marketing structure.Page: Previous 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 Next
Last modified: May 25, 2011