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
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