- 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-clearingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011