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 $165,000Page: 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011