- 6 - 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 claimedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011