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information systems Laney worked on at Dow, Lederle, Monsanto,
Merrill, and Sterling-Winthrop were designed to be able to
communicate with the computer system that would be put into place
at R.K.
Although much time, effort, and money were spent in the
design and planning of R.K., the only improvements ever made to
the Island were trails, boardwalks, and some improvements to the
landing sites. R.K. did not become operational, either as a
primate facility or as a source of data for computer systems.
Laney ordinarily did not use accountants in connection with
his consulting trade or business. However, around the start of
his work on R.K., Laney told an accountant that R.K. was separate
from his consulting activities and that he expected to put a lot
of money into R.K., and that he wanted advice as to how to
account for his R.K. expenditures for tax purposes and for
accounting purposes. The accountant advised him to separately
account for expenditures that were investments in R.K., that
Laney had a choice of deducting certain expenditures when paid or
capitalizing the expenditures and deducting them later, and that
it probably was better to capitalize and deduct later. Laney
agreed, and capitalized his R.K. expenditures. As early as 1977
Laney capitalized his expenditures for rental of certain computer
equipment used exclusively for foundation planning for R.K.
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