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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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Last modified: May 25, 2011