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one of the restaurants in which petitioner owned an interest. In
1989, petitioner paid $400 for liabilities owed to a local
garbage company. Petitioner paid $3,000 and $2,400 in the years
1989 and 1990, respectively, on a Wells Fargo Bank loan that was
taken out when petitioner acquired an interest in the Bobby
Rodgers Steak and Gourmet Burgers restaurant. Petitioner made
those loan payments when the restaurant was unable to make the
payments out of its own funds. Respondent disallowed the claimed
capital losses for all 4 years.
5. Dependent
Petitioner claimed his mother, Edith Beretta, as a dependent
on his 1990 income tax return. Mrs. Beretta suffered a stroke in
1989, as a result of which she moved into petitioner's home.
Mrs. Beretta resided with petitioner from January 1, 1990, until
October 10, 1990, at which time she returned to the hospital.
Respondent determined that Mrs. Beretta was not a dependent of
petitioner.
6. Deductions
Petitioner claimed expenses for legal fees in connection
with his ownership of various restaurants in the amounts of
$1,464, $8,354, $10,004, and $3,000 for the tax years 1987, 1988,
1989, and 1990, respectively. Petitioner expended $1,464,
$8,006, $8,267, and $3,000 for legal expenses for the tax years
1987, 1988, 1989, and 1990, respectively. The legal expenses
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