T.C. Memo. 1995-521 UNITED STATES TAX COURT BRUCE SELIG AND ELAINE SELIG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19151-93. Filed October 31, 1995. P exhibited "exotic automobiles", state-of-the- art, high technology vehicles with unique design features or equipment, for a fee. Ps claimed depreciation deductions for such automobiles. P's wholly owned S corporation made expenditures related to P's plans to open an exotic car entertainment complex. 1. Held: The exotic automobiles were subject to obsolescence and, thus, were depreciable under secs. 167 and 168, I.R.C. 2. Held, further, the expenditures made by P's wholly owned S corporation are nondeductible under sec. 162(a), I.R.C., on account of being preopening expenses not incurred in a trade or business of the corporation. 3. Held, further, the sec. 6661, I.R.C., additions to tax and sec. 6662, I.R.C., penalties determined by respondent are, in part, sustained.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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