- 4 - On November 28, 1990, petitioner withdrew $17,558 from a U.S. bank, representing money from an IRA established on his behalf by Varian (Varian IRA). On December 18, 1990, petitioner transferred $23,000 from the Bank of America to an account at a branch of the Hong Kong & Shanghai Banking Corp. located in Hong Kong. While in Hong Kong, petitioner undertook steps to develop a computer software package designed to handle currency exchange transactions. Petitioner intended to market the software package once developed. On Schedule C of his 1990 Federal income tax return, petitioner claimed a deduction of $2,618 consisting of expenses for advertising, bad debts, commissions and fees, depreciation and/or section 179 expenses, and meals and entertainment. Petitioner returned to the United States for approximately 1 month in 1991 in order to purchase a computer system for use in the development of the software package. Petitioner returned to the United States on a permanent basis in October of 1992. Petitioner signed his 1990 Federal income tax return on April 1, 1995, and the return was stamped received at the Internal Revenue Service Center in Fresno, California, on July 8, 1995. On his 1990 Federal income tax return, petitioner reported his filing status as single and claimed Schedule A deductions in the amount of $2,046 for State and local income taxes, $1,130 forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011