Basavaraj A. Hooli and Vindodini B. Hooli - Page 4




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          reported no gross receipts for the import/export activity and               
          claimed the following deductions:                                           
                                        1992                 1993                     
          Car and truck expenses        $13,941        $11,860                        
          Travel                        14,889              9,523                     
          Meals and entertainment       1,354               1,354                     
          Other business expenses       5,979               -0-                       
          Telephone                        3,956            2,388                     
          Total                         40,119         25,125                         
               Petitioner contends that his brother initially paid the bulk           
          of these expenses and that he later reimbursed his brother.  At             
          trial, petitioner attempted to substantiate, by introducing                 
          copies of traveler’s checks, that he reimbursed his brother.                
          These copies of traveler’s checks do not indicate that they were            
          cashed by petitioner’s brother.                                             
               Petitioner further asserts that HITC entered into contracts            
          with agencies of the Government of India to supply the Indian               
          Government with railroad ties.  Petitioner alleges that the                 
          contracts ultimately were canceled because he was unable to                 
          demonstrate to the Government of India and its agencies that HITC           
          was properly financed.                                                      
               Respondent determined that petitioners are not entitled to             
          deductions for the Schedule C expenses they claimed on their 1992           
          and 1993 Federal income tax returns because petitioners have                
          failed to demonstrate that the claimed expenses were incurred for           
          business purposes.  Alternatively, respondent determined that               
          petitioners failed to establish that petitioner was actively                
          carrying on a trade or business.                                            





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