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Petitioner discussed his project with an architect, but did
not retain him because the architect considered the project "too
risky". In 1977, petitioner had a patent lawyer conduct a
patentability search relating to "contoured objects such as
airfoils". The attorney advised him that there were "several
patents purportedly achieving similar results." Following that
consultation in 1977, petitioner did not contact any patent
lawyer.
Through the end of 1994, the Windmill Distillery was not
operational and had produced no alcohol.
For the years in issue, petitioner reported no gross income
while claiming the following deductions related to his Windmill
Distillery activity:
1988 1989 1990
Research
& development $44,905 $14,894 $13,780
Car & truck expense 81 --- ---
Depreciation 387 387 440
Dues & publications 80 --- ---
Insurance 55 1,863 ---
Legal & professional 1,640 309 ---
Office expense 389 581 ---
Allowable meals
& entertainment 9 --- ---
Postage --- 33 71
For 1988 through 1990, petitioner claimed business-related
meal expenses in excess of employer reimbursements in the amounts
of $609, $1,464 and $589 respectively. Respondent allowed
petitioner's meal expense deductions to the extent they were
reimbursed. Respondent disallowed the excess deductions.
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