Laura D. Seidel - Page 23

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          for cost of goods sold to $2,007 on her “amended return”.7                  
          However, as stated above, petitioner did not maintain proper                
          books or even notes to substantiate such a claim.  Therefore, we            
          hold that petitioner is not entitled to any claim for cost of               
          goods sold during the taxable year 1999.                                    
               Petitioner claimed a truck and automobile expense of $273 on           
          her original return and has increased such expense to $451 on her           
          “amended return”.  No actual log of expenses or mileage was kept            
          as to petitioner’s claimed automobile expense.  However,                    
          petitioner did keep documents of shows that she claims she                  
          attended and records of clients’ addresses that petitioner                  
          allegedly visited on business matters.  In addition, petitioner             
          introduced into evidence parking receipts from Sacramento and a             
          check from a client in the Bay Area, both of which petitioner               
          claims substantiates her travel to these areas.  Petitioner                 
          attempts to use these such documents to substantiate her claimed            
          automobile expense.  However, petitioner did not keep a mileage             
          log for such trips.                                                         
               Aside from the above-mentioned parking receipts, check, and            
          other documents, petitioner offered no further records to                   
          substantiate her travel or automobile expenses.  Her evidence               

          7Such amended return, as previously noted, was not filed                    
          with the Internal Revenue Service but was merely exchanged with             
          respondent’s counsel as part of the parties’ informal document              
          exchange.                                                                   






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