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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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