- 15 - Amortization 131 3,057 Bank charges 50 20 Prof. fees 460 --- Travel 895 --- Meals & entertainment 1,511 --- Telephone 8,941 7,276 Leasing --- 1,130 Office exp. --- 219 Postage --- 618 Total $13,218 $13,357 As to the corporation's activities in 1989 and 1990, petitioner testified that, for 1989: It was active but it was not active in marketing of the clothing at that point in time. There was not a lot of sales being generated at that point in time. We were actively marketing the fundraising at that point in time. and, for 1990: We were fulfilling all the obligations for the future shareholders as well as the shareholders that were putting Exotic Bodies together. All marketing, all research, all development. Petitioners' argument is that the corporation had entered into business in 1988 and that its expenditures in 1989 and 1990 "were to extend its existing line of business to the higher end merchandise market". Petitioners rely on Briarcliff Candy Corp. v. Commissioner, 475 F.2d 775 (2d Cir. 1973), revg. T.C. Memo. 1972-43, for the proposition that a taxpayer's expenditures in furtherance of its attempt at expansion are currently deductible under section 162(a). Respondent argues that, in 1989 and 1990, the corporation had not yet entered into a trade or business and that its expenditures during those years were nondeductiblePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011