Ahsan Mohiuddin - Page 9

                                        -  -9                                           
               Respondent in the notice of deficiency disallowed $3,464 of            
          the itemized deductions claimed by petitioner for 1991.  The                
          itemized deductions claimed by petitioner for 1991 which were not           
          disallowed were:                                                            
                    Deduction                     Amount                              
                    Real estate taxes             $277                                
                    Personal property taxes       20                                  
                    Charitable contributions      12                                  
                    Home mortgage interest        4,070                               
                    Total                         4,379                               

               Petitioner filed a Schedule C with his return for the                  
          taxable year 1991, using the business name "A & M Techservices".            
          Petitioner reported the address of this business as "1431 S. Oak            
          St. Room 16, Melbourne, FL  32901".  On the Schedule C petitioner           
          claimed business expense deductions as follows:                             
               Expense                            Amount                              
               Advertising                        $6,150                              
               Insurance                         240                                 
               Interest                           850                                 
               Legal/professional services        3,550                               
               Office expense                     7,000                               
               Equipment lease                    1,900                               
               Repairs and maintenance            775                                 
               Supplies                           200                                 
               Travel                             1,500                               
               Meals and entertainment            80                                  
               Utilities                          300                                 
               Business Start-up                  960                                 
               Total                         23,505                                   

               Petitioner stated on the Form 2106 attached to his 1991                
          return that his business was engineering consulting.  Petitioner            
          was seeking to contract out his services as an independent                  




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