Karen V. Hough - Page 8

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          expenses for each of the years 1999 and 2000.  Respondent allowed           
          $1,014 and $1,731 for 1999 and 2000, respectively.  This amount             
          included $36 for a P.O. box for both years.                                 
               Petitioner has failed to substantiate that any additional              
          amounts were paid for a P.O. box for 1999 or 2000.  Accordingly,            
          respondent’s determination on this issue is sustained.                      
               Ms. Babyak credibly testified that while she worked for                
          petitioner Fed Ex picked up packages from petitioner’s nursing              
          business approximately two times per week, but petitioner tried             
          to limit the number of pickups.  Ms. Babyak estimated the cost of           
          each pickup to be between $75 and $200.  On the basis of the                
          record, we approximate that in 2000 petitioner paid $7,800 to Fed           
          Ex.  Accordingly, in addition to the $1,695 in delivery and                 
          freight expense allowed by respondent for 2000 ($1,731 minus $36            
          for the P.O. box), petitioner is entitled to deduct an additional           
          delivery and freight expense of $6,105 for 2000.  We believe that           
          petitioner likely paid a similar amount to Fed Ex in 1999.                  
          Accordingly, petitioner is entitled to deduct her total claimed             
          postage expense, $7,204, for 1999.  Petitioner has failed to                
          substantiate that any additional amounts were paid for postage or           
          delivery expenses for 1999 or 2000.                                         











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