Ahsan Mohiuddin - Page 26

                                        -  -26                                           
          payments, airline tickets, and automobile expenses.  Petitioner             
          has not shown that the expenses for which these checks were given           
          relate to a business rather than being personal expenses.                   
               Petitioner has offered no evidence other than his vague                
          testimony that he was engaged in a trade or business other than             
          his full-time job with Avionics during the year 1991.                       
          Petitioner reported no income in 1991 from any business other               
          than his employment by Avionics.  The nature of the expenses                
          petitioner claimed as deductible in 1991 strongly suggests that             
          they were nondeductible personal household expenses.  Petitioner            
          deducted power, phone, and rent for an apartment address, which             
          he claims was his business address, at 1431 South Oak Street,               
          Room 16.  This same address appeared on the Forms W-2 issued by             
          Avionics to petitioner for the years 1990 and 1991.  This is also           
          the address that petitioner used on his checking account.                   
          Petitioner also used this address on the automobile repair                  
          invoices and on all of the car rental agreements that are in                
          evidence.  Petitioner further admitted that the South Oak Street            
          apartment is a residential apartment.  At trial, when petitioner            
          was asked where his residential address was during that year, he            
          was vague and unspecific, claiming that at the time he lived in             
          another person's house.  He had difficulty remembering the name             
          of the person, the street address, or the telephone number, but             
          could immediately recall the address that he claimed was the                
          address for his claimed business.  We conclude that petitioner              




Page:  Previous  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  Next

Last modified: May 25, 2011