T.C. Memo. 1998-307
UNITED STATES TAX COURT
WALTER J. PISZCZEK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14735-94. Filed August 24, 1998.
Ronald O. W. Ylitalo, for petitioner.
William F. Hammack, for respondent.
P, an airline pilot, spent several years and
substantial sums attempting to develop a wind-powered
distillery for the production of ethanol. For 1988
through 1990, P claimed research and experimentation
deductions under sec. 174, I.R.C., in the amounts of
$44,905, $14,894, and $13,780 respectively. R
disallowed these deductions based on a determination
that P did not expend these amounts in connection with
a trade or business, since P lacked a profit objective.
Held: P's wind-powered distillery activity was not
profit motivated.
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