Mehdi H. Hajiyani - Page 3




                                        - 2 -                                         
          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.                          
               Respondent determined deficiencies in petitioner's Federal             
          income taxes of $4,256, $6,858, and $16,977 for 1992, 1993, and             
          1994, respectively.  The issues for decision are whether                    
          petitioner:  (a) Was in the trade or business of lending money;             
          (b) and if so, is entitled to deductions for business expenses,             
          business bad debts, and the net operating losses therefrom; and             
          (c) is entitled to deduct real estate rental losses in excess of            
          $25,000.  Our resolution of these issues will determine the                 
          computational issue of whether petitioner is entitled to credit             
          for the elderly or disabled under section 22 in 1992 or 1993.               
                                     Background                                       
               The stipulation of facts and the accompanying exhibits are             
          incorporated herein by reference.  Petitioner resided in                    
          Rockville, Maryland, at the time his petition was filed in this             
          case.                                                                       
               Since 1971 petitioner has been employed as an associate                
          professor of chemistry at the University of the District of                 
          Columbia (UDC).  Petitioner was generally engaged in his                    
          professorial duties from the middle of August through the middle            
          of May.  In some years, petitioner taught evening classes and in            
          others, day classes.  Because of the lack of a graduate chemistry           








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