- 6 - 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 underPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011