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  3. Larry Lene, d/b/a CSI Mobile Home Set Up

Larry Lene, d/b/a CSI Mobile Home Set Up



Taxpayer provided on-site set up services for mobile home dealers. Taxpayer was notified of a limited scope audit (C-SPAN) based on a discrepancy between the business income reported on his 1995 federal income tax return and the receipts reported for gross receipts tax purposes.  Taxpayer was notified he had 60 days to provide evidence (NTTCs) to support any deductions claimed (Section 7-9-43). Taxpayer claimed his services were for resale and his receipts were deductible under Section 7-9-48. Taxpayer believed his accountant had obtained the necessary NTTCs, but was unable to show that the NTTCs were received timely. As a result the Department assessed the taxpayer for gross receipts tax, penalty and interest. Held:  Taxpayer was not able to show timely possession of the NTTCs required to support his deduction for services for resale. Protest denied.