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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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