Derwyn Joseph Booker - Page 7

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          Concepts and, in fact, describes himself as "not computer                   
          literate."                                                                  
               Petitioner made no attempt to market either of the video               
          games other than through ALA.  No video games were sold in 1983.            
          On April 5, 1985, petitioner received the first and only payment            
          from ALA in the amount of $3.59 representing income earned from             
          the sale of copies of the video games.                                      
               On his 1983 Federal income tax return, petitioner computed             
          an investment tax credit in connection with his involvement with            
          Century Concepts in the amount of $14,375, of which $2,751 was              
          claimed with respect to 1983.  The unused portion was carried               
          back to taxable years 1980 through 1982.  Petitioner claimed                
          deductions in the amount of $12,718 on Schedule C of his 1983               
          return with respect to Century Concepts.  Petitioner received a             
          refund in the amount of $18,105 with respect to taxable year                
          1983.                                                                       
                                       OPINION                                        
          Issue 1.  Century Concepts                                                  
               Section 162 allows a deduction for ordinary and necessary              
          expenses paid or incurred during the taxable year in carrying on            
          a trade or business.  In order to establish entitlement to                  
          deductions and credits, taxpayers have the burden of proving that           
          they meet the statutory requisites.  New Colonial Ice Co. v.                
          Helvering, 292 U.S. 435 (1934).                                             






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