- 10 - Petitioners have not shown that the $50,000 paid to RCC in 1992 was spent on research or experimentation activities. Nor have they shown a connection between any research or experimentation activities and a trade or business conducted by petitioner. Accordingly, we hold that petitioners are not entitled to deduct their $50,000 payment to RCC in 1992 under section 174. Additionally, because the activities of petitioner did not constitute a trade or business, petitioners are not entitled to deduct the expenditure as an ordinary and necessary business expense under section 162(a). Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011