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:Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011