Sam Kong Fashions, Inc. - Page 20

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          the amount of salaries and wages deducted on the corporate                  
          returns.                                                                    
               With respect to the other alleged cash wage payments, the              
          evidence is insufficient for us to estimate these amounts.                  
          Although petitioners offered timecards as evidence that Sam Kong            
          Fashions incurred additional wage expenses, we do not think that            
          these records provide a sufficient basis for estimating cash wage           
          expenses of the corporation.  Petitioners offered the timecards             
          for only a few months in 1995.  The sums listed on the timecards            
          do not indicate whether an employee was paid in cash or by check.           
          The timecards state that they are for “Shun Wo Fashions Inc.”,              
          and these records do not contain any discernable reference to Sam           
          Kong Fashions.  We find that these records fail to establish the            
          number of employees, the amount of cash that its employees were             
          paid, or the number of hours that these employees worked.  Mr.              
          Kong, who was in charge of the business, chose not to testify.              
          Because there is no credible evidence to support petitioners’               
          estimated cash wage expenses, we find that they are not entitled            
          to additional deductions for these expenses.                                
                    2.   Thread Expense in 1994                                       
               Petitioners also failed to present credible evidence to                
          support the claimed expense of $40,000 to $50,000 for thread in             
          1994.  Although Sam Kong Fashions failed to claim this deduction            
          on its 1994 corporate income tax return, it did report an expense           






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