- 19 - 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 thanPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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