- 2 - income tax purposes. Held, further, P is entitled to deduct payments to the RSC as ordinary and necessary business expenses. Sec. 162(a), I.R.C. Frederick R. Chilton, Jr., Janet S. Bianchi, Paolo M. Dau, and John J. Steele, for petitioner. Andrew P. Crousore and Ewan D. Purkiss, for respondent. GERBER, Judge: Respondent determined deficiencies in petitioner's Federal income tax as follows: Tax Year Ended Deficiency Dec. 30, 1983 $25,528,729 Dec. 28, 1984 6,245,206 Dec. 27, 1985 4,394,198 Dec. 26, 1986 4,038,178 After concessions, the issue for decision is whether payments made by petitioner to relocation service companies to assist in the disposition of the homes of its employees who relocate in connection with their employment are deductible against ordinary income or must be treated as a capital loss. FINDINGS OF FACTS1 Petitioner is a Delaware corporation with its principal place of business in Sunnyvale, California. It develops, manufactures, markets, and services large-scale computer systems, storage products, communications systems, software, and 1The parties' stipulation of facts and the attached exhibits are incorporated by this reference.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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