- 5 - of the loss was allowable. Respondent has not sought to disallow the remaining $2,379 of the loss, and we therefore do not address respondent’s calculation of the allowable amount of the loss. 2. Petitioner’s Business Activities During the year in issue, petitioner was engaged in certain business consulting activities. In connection with these consulting activities, petitioner served as the chief executive officer of an entity named North American Free Trade Association (NAFTA), which is incorporated in Mexico. In this position, petitioner would provide services to foreign companies seeking to do business in Mexico. Petitioner would allow his clients, the foreign companies, to use the address of NAFTA’s office in Mexico City. NAFTA maintained a bank account in Mexico. Petitioner also operated a business activity under the name of Occidental Utilities (OU). While petitioner entered into at least one agreement with a client in which petitioner asserted that OU was a Delaware corporation, petitioner does not recall incorporating OU, and in any event petitioner conducted business only as a sole proprietor under that name. In this business activity, petitioner provided consulting services within the utilities industry. In 1996 or 1997, petitioner entered into a contract with a business known as San Luis Tank to provide consulting services. In connection with this agreement, San Luis Tank issued petitioner a Form 1099-MISC, Miscellaneous Income,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011