- 25 - explained in INDOPCO, Inc. v. Commissioner, 503 U.S. at 86-87, it was not articulating any new legal standard in holding that capitalization is required when expenditures provide the taxpayer with significant future benefits. Petitioner has failed to prove that its $20 million contribution to VEBA II in 1985 constitutes an ordinary and necessary business expense pursuant to section 162(a). Rule 142(a); INDOPCO, Inc. v. Commissioner, supra at 84. Respondent's determination is, therefore, sustained. Decision will be entered for respondent.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Last modified: May 25, 2011