3-KOAM Company, A Partnership, My Hat, Inc., Tax Matters Partner - Page 2

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          3-Koam's 1990 U.S. Partnership Return of Income (Form 1065) of              
          $111,962.                                                                   
               After concessions by the parties,1 the issues for decision             
          are:  (1) Whether pursuant to section 174, 3-Koam may deduct                
          research and development expenses allegedly incurred in 1990.2              
          We hold it may not, except to the extent allowed by respondent.3            
          (2) Whether pursuant to section 166, 3-Koam may claim a $30,000             
          bad debt deduction in 1990.  We hold it may not.                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and the accompanying exhibits are                      
          incorporated into our findings by this reference.  At the time              
          the petition in this case was filed, 3-Koam's principal place of            
          business was in Fremont, California.  During the year in issue,             
          3-Koam used the accrual method of accounting and filed its                  
          returns on a calendar year basis.                                           


          1    For 1990, petitioner concedes the following amounts: (1)               
          ($3,629) for meals and entertainment, (2) $2,658 for automobile             
          expenses, (3) $194 for insurance, (4) $399 for depreciation, and            
          (5) $340 for interest.  These concessions will be reflected in              
          the parties' Rule 155 computation.                                          
          2    All section references are to the Internal Revenue Code in             
          effect for the taxable year in issue, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure, unless                    
          otherwise indicated.  All dollar amounts are rounded to the                 
          nearest dollar, unless otherwise indicated.                                 
          3    On its 1990 Form 1065, 3-Koam deducted $90,000 for research            
          and development; in her notice of deficiency respondent                     
          disallowed $82,000 of such amount.                                          




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