T.C. Memo. 1996-334
UNITED STATES TAX COURT
PATRICK F. AND ARLENE GWON SHEEHY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17799-94. Filed July 24, 1996.
Ralph C. Larsen, for petitioners.
Christine V. Olsen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined a $57,301 deficiency in
petitioners' 1991 Federal income tax, and an $11,460 section
6662(a) accuracy-related penalty for that year.
The issues for decision are (1) whether petitioners are
entitled to deduct as research and development expenses $165,000
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