- 11 - as well as his attorney’s statement detailing the expenses and fees incurred, and some court documents. Petitioner claimed on Schedule C $3,323 for cost of goods sold (CGS). The notice of deficiency disallowed $659 of petitioner’s claimed CGS. Petitioner’s CGS consisted of $2,833 of computer hardware and $490.39 of computer software. Petitioner provided substantiation for $58.80 in computer software receipts and was allowed a software CGS for that amount. Petitioner’s Register Report listed computer hardware items and the dates they were purchased, which respondent considered when he allowed $2,605 of petitioner’s claimed hardware items CGS. Respondent disallowed the balance of the claimed CGS for lack of substantiation and because the items were allegedly used as capital assets and not inventory.8 On his 1997 Form 1040, petitioner used his San Diego address. On his 2001 and 2002 Forms 1040, petitioner listed “2330 Candle Ridge Trail, Georgetown, TX 78626" (Georgetown, Texas, address) as his address. Form 872, Consent to Extend the Time to Assess Tax, for petitioner’s 2000 taxable year was signed by petitioner on 8The cursory revenue agent’s report does not clearly identify which hardware items were disallowed. Based on the total dollar amount disallowed of $228 ($659 total CGS disallowance minus $431 software disallowance), it appears the items were: (1) “16MB FLASH” for $70; (2) floppy drive for $65; (3) “RAM, zipdrive” for $23; and (4) a 56K modem for $70.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: November 10, 2007