- 6 - carrying on a trade or business. Sec. 162(a); Deputy v. duPont, 308 U.S. 488, 495 (1940). Petitioners deducted $24,564.98 and $10,973.16 for supplies for Keepsake in 1994 and 1995, respectively. In the examination of the 1994 return, Ms. Rhodes presented numerous receipts to substantiate the claimed deductions. Those receipts totaled almost $31,000, $6,000 more than what was claimed on the 1994 tax return. For 1995, Ms. Rhodes’s receipts from the purported suppliers, Frank’s Nursery and Crafts, Inc. (Frank’s), alone totaled $2,557.14 more than the amount claimed for supplies on that year’s return. When respondent’s examining agent questioned Ms. Rhodes about her receipts, she claimed to have purchased the bulk of her supplies from Frank’s, a significant amount from a craft store named the Silk Shop, and the remainder from various stores such as Michael’s or Wal-mart. With respect to purchases at Frank’s, Ms. Rhodes submitted to the examiner and entered into evidence at trial purchase orders from 1994 and 1995 totaling $24,076 and $13,530.30, respectively. The purchase orders were generic and bore Frank’s name and address typed in the upper left-hand corner. The transactions were handwritten and reflected that Ms. Rhodes paid cash in amounts between $2,500 and $9,000 to an individual referred to as “C.O.” for flowers, greenery, and other craftPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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