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commissioner, and realtor. For the year at issue, petitioner was
self-employed and performed business as "Les Hirahara Realty".
He reported his income and expenses from this work as a sole
proprietorship on Schedule C of his 1991 Federal income tax
return.
With respect to his activities as a realtor, petitioner
reported income and claimed certain expenses on Schedule C of his
1991 Federal income tax return that, in turn, were adjusted by
respondent in her notice of deficiency:
Amount Amount Amount
Expenses Claimed Allowed Disallowed
Interest $36,051 -0- $36,051
Depreciation 21,029 $12,142 8,887
Travel 19,027 -0- 19,027
Legal/professional 101,557 -0- 101,557
Rent 10,365 -0- 10,365
Petitioner claimed a deduction for depreciation on Schedule
C of his 1991 Federal income tax return related to the following
assets that were placed in service with petitioner's real estate
business in 1991:
Description Claimed Cost Claimed Depreciation
Equipment $31,620 $1,581
Office equipment 1,061 265
Computer equipment 5,511 1,929
Office equipment 1,800 450
Computer equipment 736 258
Office equipment 244 44
Computer equipment 5,214 1,304
Office furniture 475 85
Office equipment 1,110 119
Copier 3,849 192
Toyota van 23,709 2,660
Total: 75,329 8,887
Respondent disallowed the $8,887 claimed depreciation deduction.
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