Mehdi H. Hajiyani - Page 4




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          program at UDC, petitioner had no research responsibilities                 
          requiring additional time commitments to the school.                        
               From 1985 through 1994, petitioner reported interest income            
          from loans.  He made or purchased notes representing 75 loans in            
          amounts varying from $1,600 to $175,000.                                    
               Beginning in 1976, petitioner also engaged in purchasing               
          residential real estate for leasing and for resale.                         
               Petitioner used an enclosed deck off his master bedroom as             
          an office for his professorial, loan, and real estate activities.           
          The office had a desk, a home telephone extension, a copy                   
          machine, a computer, and miscellaneous items.                               
          Petitioner's Money-Lending Activity                                         
               Petitioner reported income from lending money beginning in             
          1985.  For each of the years 1992 and 1994, petitioner filed a              
          Federal income tax return to which he attached a Schedule C,                
          Profit or Loss From Business, reporting interest income from his            
          loan activity of $20,691 and $4,215 respectively.  For 1993,                
          petitioner received interest income from the notes he was holding           
          in the total amount of $42,597.  Petitioner, however, offset                
          against his interest income an amount claimed for bad debts of              
          $776,525 to arrive at a net bad debt loss of $733,928 reported on           
          Schedule C.  After adding the loss to claimed business expenses             
          of $28,103, petitioner reported on Schedule C a net loss from               
          business of $762,031 for 1993.                                              






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