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reference. At the time the petition was filed, petitioner's
legal residence was San Francisco, California.
Petitioner has a degree in electrical engineering from the
University of California at Berkeley. During the year at issue,
petitioner was employed as an electrical engineer by the
transportation department of the State of California known as
Caltrans. At that time, petitioner designed electrical lighting
systems for California freeways. At the time of trial,
petitioner was employed by Caltrans as an inspector of electrical
systems.
Petitioner also conducted a trade or business activity
during the year at issue known as Partners Travel (Partners).
Under the Partners name, petitioner conducted three different
types of business activities: (1) A travel agency; (2) a
computer-assisted long-distance telecommunications service to
provide customers with low rate phone calls from Mainland China
to the United States; and (3) a silk import activity.
On his Federal income tax return for 1997, petitioner
reported wage income of $69,979 from the State of California and
claimed dependency exemption deductions for two brothers, one
sister, and one aunt, totaling four dependency exemptions.
Petitioner also included with his return a Schedule C, Profit or
Loss From Business, in connection with Partners. On this
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