- 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