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office under section 280A; (2) whether petitioner is entitled to
claim a deduction for health insurance premiums; and (3) whether
petitioner is entitled to a deduction for a contribution to an
individual retirement account (IRA).
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by this reference. Petitioner filed a
timely joint Federal income tax return for 1990 with his wife,
Betty W. King (Mrs. King), now deceased. Petitioner resided in
Holly Hills, Florida, at the time he filed his petition.
In 1983, after petitioner retired from his position as a
school administrator for Fairfax County, Virginia, he and Mrs.
King moved to Holly Hills, Florida, and started a yacht charter
and brokerage business under the name of King International.
King International was a sole proprietorship with its business
office located in petitioner's home at 1402 Riverside Drive,
Holly Hills, Florida. Petitioner ran the daily operations, and
Mrs. King handled the financial end of the business.
During the year at issue, petitioner received pension income
of $44,669.45 and interest income of $12,111.23, a portion of
which he used to finance his business operations. Petitioner
owned a West Mariner 39 yacht which he used to advertise his
brokerage activities and attract charter customers for King
International. During 1990, petitioner was not employed, and,
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