- 21 - of $12,013 for the cost of threads on its 1995 corporate tax return. Petitioners did not offer any documents, such as receipts or invoices, to substantiate its claimed expense. However, petitioners rely on the testimony of Mr. Wen to support the claim. Mr. Wen stated that he was not involved in the management of the business. While he was employed by Sam Kong Fashions, Mr. Wen delivered finished products, ironed garments, and performed handiwork. We are not convinced that Mr. Wen had adequate knowledge of Sam Kong Fashions’s business operations to accurately testify about the amount of thread that Mr. Kong purchased in 1994. Additionally, representatives of Style Setters and Half Moon Bay testified that the contractors often provided the thread that Sam Kong Fashions used to sew the garments.15 Ms. Augustyn and Mr. Sporidis testified that the contractors provided some thread to Sam Kong Fashions, particularly at the beginning of their business relationship. Although the record establishes that Sam Kong Fashions did purchase thread, the evidence fails to establish whether Sam Kong Fashions incurred any expenses beyond 15 Ms. Augustyn testified that Style Setters provided thread to Sam Kong Fashions “Most of the time.” Mr. Sporidis, the president of Half Moon Bay, testified that Half Moon Bay initially provided thread to the corporation. Later, Half Moon Bay stopped providing the corporation with thread because “[Half Moon Bay] would never get [the thread] back” and “it became a big cost”.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011