Hugh G. and Norma J. King - Page 19

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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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