Leonard Charles and Kaye Layne Ekman - Page 6

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          of deficiency, conceded petitioners' entitlement to a deduction             
          of various expenses for research or experimentation on the                  
          subject engine:  $3,050 for cam development, $2,120 for piston              
          development, $4,135 for engine block development, and $2,000 for            
          cylinder head development, totaling $11,305.  Respondent                    
          maintains that the $7,000 paid by petitioner for the damaged                
          Porsche 928 S4 engine does not constitute a research or                     
          experimentation expense on the ground that the engine constituted           
          the acquisition of another's patent, model, production, or                  
          process under section 1.174-2(a)(1), Income Tax Regs., and,                 
          therefore, the cost of the engine is not deductible.  Respondent            
          further contends that the engine was an asset used in connection            
          with research or experimentation under section 1.174-2(b)(1),               
          (2), and (4), Income Tax Regs., and, therefore, could not be                
          expensed but could only be depreciated.  However, respondent                
          further contends that no depreciation should be allowed because             
          the engine was not placed in service during 1991.                           
               Petitioners contend that the $7,000 cost of the engine                 
          constitutes a research or experimentation expense that is fully             
          deductible in 1991 under section 174(a) or, alternatively, under            
          section 179, or, as a final alternative, that the cost of the               
          engine may be depreciated under section 167.                                
               Deductions are a matter of legislative grace, and the                  
          taxpayer must satisfy the specific statutory requirements claimed           





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