- 26 - amount of $13,850, and "Disallowed investment interest expense" in the amount of zero. The Takaos reported "Deductible investment interest" in the amount of $13,850 on Schedule A-- Itemized Deductions for 1991, purportedly based on imputed interest on a loan from Hada.11 Throughout their association, Yoshinori was involved in several financial dealings with Nakamura, and he trusted and relied on Nakamura. Yoshinori delegated many of his financial affairs to Nakamura. Nakamura is listed as a signatory on the Takaos' business checking account. He prepared the Takaos' tax returns for the years 1988 through 1991 as well as Toraya's tax returns for the same years. The Takaos' 1988 tax return was filed October 3, 1990. Respondent granted the Takaos an extension to file their 1988 tax return until October 15, 1989. Facts Relating to Toraya When it filed its petition, Toraya maintained its principal place of business in San Francisco, California. Toraya was an accrual basis taxpayer. In 1985, Toraya began changing its restaurants' menus from standard sitdown restaurant fare to sushi bar fare. However, the restaurants did not maintain a straight sushi bar menu. At that time, the sushi bar concept was known in Japan, but not common in 11 There is no evidence that any interest was in fact paid, that it was declared by Hada, or whether it would have qualified as investment interest.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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