Sam Kong Fashions, Inc. - Page 22

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          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.                                                                  







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