- 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