Leslie S. Hirahara - Page 10

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          we allow depreciation with respect to these particular items in             
          question.                                                                   
               Petitioner purchased a Toyota Previa van for his company for           
          $23,038.50 from Thomason Toyota.  He bought the van in Oregon.              
          He also expended $670.60 to ship the van to Hawaii from the                 
          mainland.  Petitioner stated that the van was strictly utilized             
          for business purposes.  Ultimately, however, petitioner did not             
          meet the standard required by section 274 to show the vehicle's             
          business usage.  See sec. 1.274-5T(a), Temporary Income Tax                 
          Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).  With respect to the              
          remaining expenditures, petitioner's testimony was vague and                
          self-serving.  For example, according to petitioner's testimony,            
          and the canceled checks submitted for the record, he purchased              
          various pieces of office equipment in 1991.  However, petitioner            
          has failed to substantiate the extent to which office equipment,            
          such as chairs from Ushijima, was used in his trade or business.            
          Petitioner was also unable to recollect the reasons for the                 
          amounts paid to Sears, Shirokiya, and American Express.  As                 
          petitioner has failed to specify the business purpose of these              
          particular expenses, we sustain respondent's determination                  
          disallowing these deductions.                                               
               C.  Travel Expense Deduction                                           
               Petitioner claimed a travel expense deduction in the amount            
          of $19,027 on Schedule C of his 1991 Federal income tax return.             
          Respondent disallowed this deduction in its entirety in the                 
          statutory notice of deficiency.                                             



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