- 22 - those reported on its 1995 corporate income tax return. Again, we note that Mr. Kong did not testify. We find that petitioners failed to substantiate the claimed additional thread expenses in 1994. 3. Additional Depreciation Deductions Petitioners argues that they are entitled to depreciation deductions for machines that were not listed on the depreciation schedule prepared by Kim Y. Ling, P.C. In calculating the additional depreciation deductions, petitioners rely on the testimony of Mr. Wen. We find that Mr. Wen testified inconsistently with regard to his duties and responsibilities at Sam Kong Fashions. Regarding his role in the purchase of equipment, Mr. Wen testified that he sometimes made withdrawals from the Corestates checking account “to buy some factory machines, sewing machines.” However, when asked whether his responsibilities at the corporation included paying bills, Mr. Wen indicated that his job was “to pick up and deliver the finished product, and do the handiwork.” With respect to the payroll, Mr. Wen testified that he made withdrawals from the Corestates checking account “[Sometimes] to make payrolls”, but later testified that he was not responsible for the payroll. Because of these inconsistences, we do not rely on Mr. Wen’s testimony.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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