Shigenori Kudo and Motomi Kudo, et al. - Page 24

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               For 1988, the Takaos filed Form 4952, Investment Interest              
          Expense Deduction, with their tax return on which is reflected              
          "Interest expense on investment debts paid or accrued in 1988" in           
          the amount of $55,320, "Allowed investment interest expense" in             
          the amount of $49,299, and "Disallowed investment interest                  
          expense" in the amount of $6,021.  The Takaos reported                      
          "Deductible investment interest" in the amount of $49,299 on                
          Schedule A--Itemized Deductions for 1988.                                   
               For 1989, the Takaos filed Form 4952, Investment Interest              
          Expense Deduction, with their tax return on which is reflected              
          "Investment interest expense paid or accrued in 1989" in the                
          amount of $32,334, "Disallowed investment interest expense from             
          1988" in the amount of $6,021, "Investment interest expense                 
          deduction" in the amount of $38,355, and "Disallowed investment             
          interest expense" in the amount of zero.  The Takaos reported               
          "Deductible investment interest" in the amount of $38,355 on                
          Schedule A--Itemized Deductions for 1989.  On Schedule B of the             
          tax return he filed for 1989, Nakamura reported income of $30,000           
          from Yoshinori.                                                             
               For 1990, the Takaos filed Form 4952, Investment Interest              
          Expense Deduction, with their tax return on which is reflected              
          "Investment interest expense paid or accrued in 1990" in the                
          amount of $30,000, "Investment interest expense deduction" in the           
          amount of $30,000, and "Disallowed investment interest expense"             
          in the amount of zero.  The Takaos reported "Deductible                     




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