Basavaraj A. Hooli and Vindodini B. Hooli - Page 3




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               Respondent determined deficiencies in petitioners’ Federal             
          income taxes for 1992 and 1993 of $7,796 and $5,140,                        
          respectively.  The issues for decision are:  (1) Whether                    
          petitioners have substantiated their claimed deductions for                 
          expenses reported on Schedule C, Profit or Loss From Business,              
          for 1992 and 1993, and (2) whether petitioners’ import/export               
          activity was functioning during 1992 and 1993 or still was in a             
          preopening or startup situation.                                            
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioner Basavaraj A.             
          Hooli resided in Daleville, Alabama, and Vinodini B. Hooli                  
          resided in St. Petersburg, Florida, when the petition in this               
          case was filed.  References to petitioner in the singular are to            
          petitioner Basavaraj A. Hooli.                                              
               During the years in issue, petitioner was employed as a                
          medical technician.  From this employment, petitioner reported              
          wage income of $40,497 and $44,305 for 1992 and 1993,                       
          respectively.  Petitioner contends that during these years he               
          worked as a medical technician only on weekends.                            
               Petitioner also contends that during 1992 and 1993, he and             
          his brother, who lived in India, engaged in an import/export                
          activity named “H.I.T.C. USA” (HITC).  On Schedules C attached to           
          petitioners’ 1992 and 1993 Federal income tax returns, petitioner           






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