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Petitioner earned nearly all of her tax preparation income
between January 1 and April 15 of each year.
During petitioner's criminal proceedings, petitioner and her
attorneys were informed that they could examine her seized
records or take them back at anytime. Petitioner retrieved her
records sometime in 1998 and placed them in storage in
Sacramento, California. Petitioner did not get the records out
of storage until December 1998 when petitioner satisfied storage
fees in arrears.
In 1989, petitioner lent Penisimani Lomu and Hakeai Faanunu
$13,300 bearing 9 percent interest. Petitioner was paid $1,097
and $399 in interest during 1990 and 1991, respectively.
During 1990, 1991, and 1992, petitioner paid to John
Giovanzana $950, $10,497, and $7,588, respectively, in rent for
business premises at 1923 University Avenue, East Palo Alto,
California. During 1990, petitioner paid Siri Brothers $26,096
in rent for business premises at 645 Donohoe Street, East Palo
Alto, California; petitioner was evicted on April 15, 1990.
Respondent has allowed a deduction for rent expense in the
amounts of $27,046, $10,497, and $7,588, respectively, for
petitioner's 1990, 1991, and 1992 taxable years.
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