13
Respondent acknowledges that the cost of developing computer
software may qualify as research and experimental expenses.
Petitioner contends that expenditures for "utilities" and
"rent or lease" relate to the business use of his home.
Petitioner's wife testified that one room in their home was
petitioner's office. We have insufficient evidence regarding the
portion of petitioner's home used for business purposes, and he
offered no evidence regarding the hours spent at his home for
business purposes or the business activities performed at his
home. We find that petitioner has not substantiated the
expenditures related to the business use of his home. We sustain
respondent's determination as to these items.
Petitioner has shown that the remaining expenditures he
reported on the Schedules C were associated with the Food Store,
and we now turn to whether they are deductible pursuant to
section 174.
Petitioner paid consulting fees to Voiland, Hendricken, and
Akabas. Voiland testified that he advised petitioner about
natural foods stores, how they are set up, and the types of
products sold in them. Voiland's advice included drawing and
modifying floor plans for a natural foods store. Hendricken
helped petitioner prepare a business plan. We find that these
activities did not relate to the development of computer
software.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011