3
In 1990, petitioner formed NSA, and, according to his
testimony, began looking for real estate investments. In 1991,
petitioner passed his real estate agent examination and
associated NSA with Marilyn Taylor, a real estate broker.
Petitioner did not invest in, sell, or renovate any real estate
during 1991. On November 8, 1991, while on disability leave from
Whittlesea Cabs and receiving worker's compensation, petitioner
traveled to Alaska for the purported purpose of investing in real
estate.
From November 12 until November 19, 1991, petitioner stayed
at the Best Western Hotel in Juneau, Alaska. On November 26,
petitioner entered into a 6-month lease with Patrick Macksey as
co-tenant for a three-bedroom house at a monthly rent of $1,100.
Under the terms of the lease, petitioner agreed not to paint,
paper, or otherwise redecorate or make alterations to the
premises without prior written consent of the owner. The initial
payment, including security deposit and first month's rent, was
$1,883.33.
Due to a lack of available treatment for his ongoing medical
problems, petitioner departed Alaska on December 24 and returned
to Nevada on or about December 27, 1991. Petitioner did not
invest in any real estate or attend any business meetings with
bankers or realtors while in Alaska.
On Schedule C attached to his 1991 Federal income tax
return, petitioner claimed the following business deductions:
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Last modified: May 25, 2011