Leslie S. Hirahara - Page 9

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          placed in service in 1991.  Respondent concedes petitioner’s cost           
          basis in some of the equipment, but contends that petitioner has            
          not demonstrated a nexus between the purchases and petitioner's             
          business use.                                                               
               Petitioner placed on the record certain checks he issued in            
          1991 to certain payees as follows:                                          
          Payee                 Amount          Entry                                 
          Sears, Roebuck and Co. $1,800.00   Office equipment                         
          Mr. Software        736.00         Office equipment                         
          Shirokiya           244.14         Office phone                             
          Mr. Software        4,572.00       Computer soft                            
          Ushijima            475.00         [Blank]                                  
          Mr. Software        641.93         [Blank]                                  
          American Express    752.09         3728-126520-01007                        
          University Copy                                                             
          Systems of Hawaii   3,849.08       Sales No. 0CSA08                         
          Shirokiya           1,060.68       [Blank]                                  
          Sears, Roebuck and Co.  1,110.35   8-93667 73315 6                          
          Thomason Toyota     23,038.50      Auto                                     
          Matson Navigation Co.    670.60    Shipment No. MNCHF4933                   
          Petitioner also supplied a price quotation issued by Pacific                
          Machinery to him on December 18, 1991.                                      
               At trial, petitioner introduced canceled checks,                       
          attributable to a variety of expenditures, related to his real              
          estate proprietorship.  Many of these expenditures are business             
          related.  Petitioner purchased software and computers in                    
          connection with his real estate business from Mr. Software.  He             
          utilized the computers for word processing and accounting                   
          functions, as well as to call on a database of listings on                  
          properties.  Petitioner purchased a recording telephone with two            
          lines from Shirokiya for $244.14.  He also acquired a fax machine           
          from University Copy Systems of Hawaii for $3,849.08.  These                
          items were utilized in his real estate business office.  Hence,             




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