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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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