- 3 -
2. Whether petitioner may deduct self-employment expenses
in amounts greater than allowed by respondent. We hold he may to
the extent stated herein.
FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulated facts and the exhibits submitted therewith are
incorporated herein by this reference. At all relevant times,
petitioner resided in a 542-square-foot apartment in a large
building located on 6.7 acres of land at 5522 (A1A) N. Oceanside
Blvd., Palm Coast, Florida (the Oceanside Blvd. property).
Petitioner purchased the Oceanside Blvd. property (inclusive of
the apartment) in 1976 and operated on it a sole proprietorship
named “Kenneth L. Ihlenfeldt d/b/a/ Delta Marine Enterprises”
(Delta). Delta’s primary business activity was the building,
repairing, and storing of boats. In addition to the apartment,
the building on the Oceanside Blvd. property contained vast space
for the storage of boats and boat parts, a small business office
with a desk and a telephone, and a second office where petitioner
kept business documents.
During 1989, petitioner purchased a second property (the
second property) in Palm Coast, Florida. He operated on the
second property a C corporation named Seven Leagues Charter, Inc.
He began operating in 1990 another C corporation named Omega
Yachts, Inc. Petitioner performed backhoe work and land-clearing
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011