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and development as well as farming activities on the 80 acres
allocated to Utah I.
We also hold that Utah I had no realistic prospect of
entering into a trade or business with regard to the technology
that was to be developed by U.S. Agri. The Supreme Court's
decision in Snow v. Commissioner, supra, "makes it important to
determine whether the prospects for developing a new product that
will be exploited in a business of the taxpayer are realistic".
Spellman v. Commissioner, 845 F.2d 148, 149 (7th Cir. 1988),
affg. T.C. Memo. 1986-403. Unless the taxpayer can show that
there is a realistic prospect that he will ultimately engage in a
trade or business that exploits the developed technology, a
research and experimental expenditure cannot be said to have been
paid or incurred "in connection with" a trade or business.
Harris v. Commissioner, 16 F.3d 75, 81 (5th Cir. 1994), affg.
T.C. Memo. 1990-80, supplemented by 99 T.C. 121 (1992); Zink v.
United States, supra at 1023; Spellman v. Commissioner, supra at
148-149; Diamond v. Commissioner, 92 T.C. 423, 439 (1989), affd.
930 F.2d 372 (4th Cir. 1991).
The management of investments, however, is not a trade or
business, regardless of how extensive or complete the portfolio
or how much time is required to manage the investments. Green v.
Commissioner, supra at 688-689. This Court and other courts have
scrutinized claimed research and development expenditures to
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