- 4 - for research or experimentation undertaken directly by him but also to expenditures paid or incurred for research or experimentation carried on in his behalf by another person or organization". Deductions are a matter of legislative grace, and the taxpayer has the burden of demonstrating that he is entitled to a deduction. New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). The burden of proof remains on the taxpayer even when the case is submitted fully stipulated. Borchers v. Commissioner, 95 T.C. 82, 91 (1990), affd. 943 F.2d 22 (8th Cir. 1991). Petitioners have adequately substantiated that they paid $50,000 to RCC in 1992. To be entitled to the deduction, however, they must demonstrate that the amount was actually spent for research or experimentation conducted by them or on their behalf in connection with their trade or business. See Grindle v. Commissioner, T.C. Memo. 1993-297. Petitioners' evidence consists of two documents. First, on the Schedule C of their 1992 Federal income tax return, they list RCC as petitioner's business. They describe its function as "Manufacturing Recyclable containers" and indicate that petitioner "materially participated". Plainly, petitioners' Schedule C is self-serving, and hardly represents convincing evidence on their behalf.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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