Sam Kong Fashions, Inc. - Page 17

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               We find that respondent has proven by clear and convincing             
          evidence that Sam Kong Fashions received and failed to report               
          gross receipts in 1994 and 1995.  On the basis of the customers’            
          payments for sewing services, we find that Sam Kong Fashions                
          received total gross receipts of $616,574.25 in 1994 and                    
          $521,214.64 in 1995.  On its corporate income tax returns, Sam              
          Kong Fashions reported gross receipts in the amount of $224,718             
          and $217,296 in 1994 and 1995, respectively.  Therefore, we find,           
          by clear and convincing evidence, that the unreported gross                 
          receipts of Sam Kong Fashions totaled $391,856.25 in 1994 and               
          $303,918.64 in 1995.                                                        
               B.   Unreported Business Expenses                                      
               Section 162(a) provides a deduction for all ordinary and               
          necessary expenses paid or incurred in carrying on a trade or               
          business.  Taxpayers bear the burden of proving that they are               
          entitled to any claimed deductions.  Rule 142(a); INDOPOC, Inc.             
          v. Commissioner, 503 U.S. 79, 84 (1992).                                    
               Section 6001 provides that a taxpayer must substantiate any            
          deductible expenses claimed.  Taxpayers are required to maintain            
          records that sufficiently establish the amount of claimed                   
          deductions.  Sec. 6001; sec. 1.6001-1(a), Income Tax Regs.  When            
          taxpayers present convincing evidence that they incurred                    
          deductible expenses, but lack the records to substantiate the               
          claimed amounts, courts may estimate the allowable deductions.              






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