- 35 - 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.”Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: November 10, 2007