Gary Lee Colvin - Page 35




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          indicated petitioner paid $500 for her services.  The invoice               
          specifically referenced payment by check No. 6718, which                    
          apparently never cleared petitioner’s bank account.  Petitioner             
          has failed to substantiate his claimed accounting, tax                      
          preparation, and representation fees.  Accordingly, the Court               
          sustains respondent on this issue.  Petitioner is not entitled to           
          a deduction for accounting fees.                                            
               F. Cost of Goods Sold                                                  
               “The cost of goods purchased for resale, with proper                   
          adjustment for opening and closing inventories, is deducted from            
          gross sales in computing gross income.”  Sec. 1.162-1(a), Income            
          Tax Regs.  A taxpayer may also deduct the cost of supplies and              
          materials consumed in the operation of his or her business during           
          the taxable year.  See sec. 1.162-3, Income Tax Regs.                       
               Petitioner claimed on Schedule C $3,323 for CGS.  Respondent           
          disallowed $659 of petitioner’s CGS.  Petitioner asserted that he           
          purchased the items constituting his CGS for use in his sales               
          activity for TIG and then provided substantiation for $58.50 in             
          computer software.20  The remaining items listed as his CGS were            
          allegedly used in his computer assembly and consulting business,            
          Computer Consulting Forum Company.  Petitioner claimed to have              

               20Petitioner contended that he purchased a Palm Pilot which            
          he “used for appointments” that were “related to * * * [his]                
          business.”  Petitioner further testified that the Palm Pilot                
          “actually got run over by a car and flattened.  So it was a total           
          loss that year.”                                                            






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