Kai-Chung C. and Meekhing T. Lam - Page 3

                                         -3-                                          
          Petitioners resided in Cordova, Tennessee, at the time they filed           
          the petition.                                                               
               Mr. Lam (petitioner) was self-employed during the years at             
          issue.3  Petitioner owned and operated two businesses during the            
          years at issue; an investment and insurance business, and a real            
          estate business.  All the business income and expenses in dispute           
          relate to the operation of these two businesses.                            
               Petitioner’s “major business” is the investment and                    
          insurance business, in which petitioner, a certified financial              
          planner, provided clients investment services and sold insurance            
          products.  Petitioner also is a licensed realtor and operated his           
          real estate business, Cordova Realty, as a “sideline.”  Cordova             
          Realty’s business included renting, managing, and selling                   
          properties.                                                                 
          I.   Income Tax Returns for the Years at Issue                              
               Petitioners filed joint income tax returns that petitioner             
          prepared, including detailed depreciation schedules.  Petitioners           
          reported the income and expenses from petitioner’s two businesses           
          on Schedule C, Profit or Loss From Business.                                
               A.   Schedule C Deductions                                             
               Petitioners claimed deductions for, among other things,                
          repair and maintenance, supplies, bad debt, office, insurance,              


               3Mrs. Lam is a party to this case because she filed joint              
          returns with petitioner.                                                    





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Last modified: May 25, 2011