Leonard Charles and Kaye Layne Ekman - Page 2

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          (1) Whether petitioners are entitled, under section 174(a), to a            
          deduction for the cost of an automobile engine that was used in             
          connection with a research or experimentation activity of Leonard           
          Charles Ekman (petitioner); (2) if the automobile engine is not             
          deductible as a research or experimentation expense, whether the            
          cost is deductible under section 179; and (3) if the cost of the            
          automobile engine is not deductible under either section 174(a)             
          or section 179, whether the engine is depreciable under section             
          167.                                                                        
               Some of the facts were stipulated.  Those facts, with the              
          annexed exhibits, are so found and are incorporated herein by               
          reference.  At the time the petition was filed, petitioners,                
          husband and wife, were legal residents of Panama City, Florida.             
               Although the issues in this case involve one item, an                  
          automobile engine that was used in a research and experimental              
          activity, there are several other adjustments in the notice of              
          deficiency as to which the parties reached a basis for settlement           
          prior to trial.2                                                            

               2    On their income tax return, petitioners claimed                   
          Schedule A itemized deductions of $11,819.  In the notice of                
          deficiency, respondent disallowed these expenses as itemized                
          deductions but allowed Schedule E expenses on rental property of            
          $12,725 and $1,790 for depreciation.  Petitioners agree to these            
          adjustments.  On Schedule C of their income tax return, relating            
          to petitioners' research or experimental activity, petitioners              
          claimed expenses totaling $18,305 that respondent totally                   
          disallowed.  Respondent, however, allowed a deduction, under                
          Schedule C, in the amount of $609, for expenses petitioners had             
                                                             (continued...)           




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