Mary K. Fisher and Charles F. Patterson, et al. - Page 6

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          on the date it disappeared.  Upon examination, respondent                   
          disallowed the claimed deductions, asserting that petitioners had           
          presented no evidence regarding their cost basis in either Since            
          Gussie or the puppy.                                                        


               (b)  Amortization of Startup Expenditures for 1991 and 1992            
               Prior to commencing operation of Arabian Hill in 1988,                 
          petitioners acquired horses and related assets during the years             
          1982 through 1987.  Petitioners estimate that they incurred                 
          startup expenditures related to Arabian Hill in the amount of               
          $20,370.  Petitioners itemize their claimed startup expenditures            
          as follows:                                                                 
               Research--assessing viability                    $1,680                
               Asset search                                      3,130                
               Seminars, clinics, and other events               3,060                
               Tack and supplies                                10,000                
               Other developmental expenditures                  2,500                
                    Total                                       20,370                
          Petitioners assert that they are entitled to amortize these                 
          expenditures as start-up expenditures, beginning with the taxable           
          year 1988 and continuing for the following 4 years.  Accordingly,           
          on each of their 1991 and 1992 returns, petitioners claimed an              
          amortization expense deduction in the amount of $4,074,                     
          attributable to these purported expenditures.  Upon examination,            
          respondent disallowed petitioners' claims for amortization                  
          deductions, asserting that petitioners had failed to make a                 
          timely election to amortize the startup expenditures under                  




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