- 4 - On November 18, 1991, the Skin Service Club, Inc. (Skin Service Club), was incorporated as a C corporation under California law. Petitioner and his brother, David Sywehong Chin, each owned 50 percent of the Skin Service Club stock. Two years later, on November 15, 1993, the Skin Service Club elected to be taxed as an S corporation. The Skin Service Club conducted business at the Sherman Oaks Property in 1992, 1993, and 1994. Petitioner, however, did not acquire, in his name, any City of Los Angeles permits or licenses needed to conduct business in the town of Sherman Oaks. In addition, petitioner never maintained a medical or surgical listing in any Sherman Oaks telephone directory, and he was not a member of the Los Angeles County Medical Society. For both years at issue, the Skin Service Club reported zero gross receipts. Further, the Skin Service Club did not generate any revenue from the time of its conversion to an S corporation through December 30, 1996, when the company was dissolved. During its entire period of operation, the Skin Service Club did not claim any rent expense relating to the Sherman Oaks Property. On November 13, 1991, petitioner executed a 10-year lease on suite B of the Sherman Oaks Property, with petitioner’s mother as landlord. Under the terms of the lease, petitioner made rent payments to his mother of $52,000 in 1994 and $48,000 in 1997. Petitioner deducted these amounts as business expenses on hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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