Leslie S. Hirahara - Page 2

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               After concessions, the issues remaining for our                        
          consideration are:  (1) Whether petitioner is entitled to claim             
          an interest expense deduction for his sole proprietorship                   
          activity reported on Schedule C of his 1991 Federal income tax              
          return; (2) whether petitioner is entitled to claim depreciation            
          for certain items purchased in 1991; (3) whether petitioner is              
          entitled to claim a deduction for travel expenses for 1991; (4)             
          whether petitioner is entitled to claim a deduction for legal and           
          professional services for 1991; (5) whether petitioner is                   
          entitled to claim a deduction for rent paid in 1991; (6) whether            
          petitioner understated his capital gain on Schedule D of his 1991           
          Federal income tax return; (7) whether petitioner is entitled to            
          an increase in his itemized deductions for the 1991 taxable year;           
          and (8) whether petitioner is liable for an accuracy-related                
          penalty pursuant to section 6662(a) for the 1991 taxable year.              
                                  FINDINGS OF FACT2                                   
               Petitioner, Leslie S. Hirahara, resided in Honolulu, Hawaii,           
          at the time the petition in this case was filed.  He possesses a            
          master's degree in business administration in finance.                      
          Petitioner, at various times, has been engaged in multiple                  
          business activities.  These enterprises encompassed occupations             
          such as a general contractor, flight instructor, county                     


               2 The parties' stipulation of facts and exhibits are                   
          incorporated by this reference.                                             




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