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2. Costs of Goods Sold for 1996 and 1998
Petitioners contend that respondent incorrectly calculated
their costs of goods sold for 1996 and 1998. We disagree.
Petitioners cite UAL Corp. v. Commissioner, 117 T.C. 7, 10
(2001), in which we dealt with deductions of per diem allowances
paid to employees. Petitioners do not explain how UAL applies to
this case or give any grounds supporting their contention.
3. Whether Respondent Incorrectly Calculated Cost of Goods
Sold for King’s Appliances, Inc., for 1997
Petitioners contend that respondent incorrectly calculated
the adjustment for returns and allowances for goods sold from
King’s Appliances, Inc., for 1997. They contend that their
records state that the amount for returns and allowances for 1997
is $37,119, and not $33,924 as allowed by respondent. However,
petitioners did not provide those records or offer any other
evidence to corroborate their claim. We sustain respondent’s
determination on this issue.
4. Conclusion
We conclude that respondent correctly determined
petitioners’ costs of goods sold for 1995-98.
D. Whether Petitioners Are Entitled to Larger Deductions for
Depreciation Than Respondent Allowed
Petitioners contend that their basis in the South Oates and
Ross Clark buildings is larger than respondent determined, and
thus they may deduct more depreciation for those properties than
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