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were also other receipts related to food from Aramark in the
amount of $67, Mission Burritos Carillon for $13.21, and Frankie
B. Mandola’s for $26.26. Some of the receipts had no dollar
figures, and the connection of these expenses, if any, with
Frexie is largely unexplained. The Court holds that these
expenses have not been adequately substantiated and, therefore,
are not deductible.
On Schedule A for the year 2000, petitioner claimed a
deduction of $3,218 for the writeoff of old inventory.
Petitioner testified that he had been in the water filter
business in prior years. After the business was discontinued, he
had on hand an inventory of unsold water filter units.
Petitioner presented at trial a copy of a 1989 Schedule C
relating to the activity that reflected an inventory valuation of
$3,218 in connection with an environmental equipment sales
business. Petitioner testified that he reported his income and
expenses from that activity on Schedule C of his 1989 income tax
return.
Petitioner testified that the business languished for a long
period of time and was discontinued, presumably sometime after
1989. He had inventory remaining from the business that was
never sold. He had received an offer to sell the inventory in
November 1999 for “50 cents on the dollar”, which he declined.
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