Leslie S. Hirahara - Page 8

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          of principal and interest.  The signature on the check is                   
          illegible.  Stamped on the face of petitioner's check is the                
          notation, dated October 2, 1991, that the check was returned due            
          to "Endorsement Irregular/ ENDORSEMENT MISSING".                            
               On December 27, 1991, through business check No. 1983,                 
          petitioner paid $1,000 to the order of Steven Hirahara.  The                
          check was from "Les Hirahara - Realtor".  The memo portion of               
          this check states that it is for the payment of interest.                   
               The evidence offered is insufficient to show petitioner's              
          entitlement to the interest deduction.  The payment to Nuuanu               
          Streamside, Inc., was not made because the check was returned due           
          to an irregularity.  The only evidence pertaining to the interest           
          deduction is petitioner's unsubstantiated testimony.  He did not            
          proffer the testimony of a representative from Nuuanu Streamside,           
          Inc., nor his brother's testimony (Steven Hirahara) in an attempt           
          to corroborate petitioner's stated reasons for the payments.                
               Moreover, petitioner did not document the purported loan               
          amounts, the amounts of interest payable, or the terms of                   
          payment.  The notations on the submitted checks are insufficient.           
          Petitioner's failure to provide corroborative evidence presumably           
          in his control weighs against him.  Tokarski v. Commissioner, 87            
          T.C. 74 (1986).                                                             
               Respondent is sustained on this issue.                                 
               B.  Depreciation Expense Deduction                                     
               Petitioner claimed a deduction for depreciation on Schedule            
          C of his 1991 income tax return with respect to assets that were            



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