- 7 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011