Kevin R. Johnston - Page 8




                                        - 8 -                                         

          During 1993, a checking account at the Bank of California (the              
          Universal account) was held in Universal’s name.  Petitioner and            
          Ms. Ghavami were signatories on this account and wrote checks on            
          the account during 1993.                                                    
               As the parties have stipulated, $104,786 was deposited in              
          the Universal account during 1993; of this amount, $103,420 was             
          paid by third parties for work done by petitioner, and $1,341 was           
          paid for work done by Ms. Ghavami.  Thus, all but $25 of the                
          $104,786 deposited into the Universal account during 1993 was               
          paid as consideration for services performed by petitioner or Ms.           
          Ghavami.                                                                    
               After review of some canceled checks drawn on the Universal            
          account, respondent has conceded that petitioner is entitled to             
          deduct, as trade or business expenses, $914 paid by Universal for           
          postage, $220 paid by Universal to sponsor sports teams, and $441           
          paid by Universal for printing.                                             
               Petitioner does not have, and did not maintain during 1993,            
          a record of his business and personal automobile mileage.                   
               The amount of the distribution deduction claimed by                    
          Universal on its 1993 return, $31,210, was equal to the entire              
          net income shown on the return.  The return states that the                 
          $31,210 was distributed to an entity known as “Oak Hargor [sic]             
          Finance”, with the following address: “P.O. Box 577, Guelth                 
          [sic], Ontaria [sic] Canada N1H 6K9".                                       





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011