- 2 - Leslie J. Schneider, Patrick J. Smith, Frederic G. Corneel, and Kenneth J. Seaman, for petitioner. Steven R. Winningham, Martin L. Shindler, Marvis A. Knospe, and Tyrone J. Montague, for respondent. RUWE, Judge: Respondent determined deficiencies in petitioner's Federal income taxes as follows: Year Deficiency 1985 1$111,905 1986 534,142 1987 99,042 1Respondent was granted leave to amend the answer, asserting that petitioner is liable for an increased deficiency for 1985 in the amount of $48,156. Thus, the total deficiency determined by respondent for 1985 is $160,061. The issues for decision are: (1) Whether the costs petitioner incurred in starting new regulated investment companies during the years in issue are deductible as ordinary and necessary business expenses under section 1621 or must be capitalized; and (2) if the costs are capital expenditures, whether petitioner is entitled to deduct an amortized portion of such costs under section 167. 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect during the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 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