Bruce Selig and Elaine Selig - Page 15

                                       - 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 nondeductible                 





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