- 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