Reza and Connie M. Rezazadeh - Page 2

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               Respondent determined the following deficiencies in                    
          petitioners' Federal income taxes and penalties:                            
            Penalty                                                                   
          Year          Deficiency             Sec. 6662(a)                           
               1990           $3,161                   $632                           
               1991           6,003                    943                            
               1992           5,284                    288                            

               After concessions by the parties,2 the issues remaining for            
          decision are:  (1) Whether petitioners are entitled to a business           
          bad debt deduction for 1989 under section 166(a) for unpaid loans           
          to a corporation in which Reza Rezazadeh (petitioner) was an                
          employee/shareholder and for attorney's fees incurred in attempts           
          to collect the loan; (2) whether petitioners are entitled to                
          deductions under section 162(a)(2) for travel expenses incurred             
          by Connie M. Rezazadeh (Mrs. Rezazadeh) during 1991; (3) whether            
          petitioners' deduction for 1992 under section 162(a) of inventory           


          2                                                                           
               Petitioners claimed, on their 1990 and 1991 Federal income             
          tax returns, deductions for unreimbursed employee expenses in the           
          amounts of $7,093.04 and $10,274.90, respectively.  In the notice           
          of deficiency, respondent disallowed $3,165 and $8,111 of the               
          amounts claimed, respectively.  In a stipulation of settled                 
          issues (stipulation), petitioners conceded the entire                       
          disallowance for 1990 and $6,585.68 of the disallowance for 1991.           
          Accordingly, with respect to the deduction claimed for 1991,                
          $1,525.32 of the disallowance remains at issue, which is issue              
          number (2) above.                                                           
               On their 1991 return, petitioners also claimed a deduction             
          of $466.25 for sales taxes paid on an automobile.  In the notice            
          of deficiency, respondent disallowed the deduction in its                   
          entirety.  In the stipulation, petitioners conceded this                    
          adjustment.                                                                 





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