Utah Jojoba I Research, William G. Kellen, Tax Matters Partner - Page 48

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          mechanism to disguise the capital contributions of the limited               
          partners as currently deductible expenditures and thus reduce the            
          cost of their participation in the farming venture.                          
               Accordingly, we hold that Utah I is not entitled to deduct              
          its losses for research or experimentation expenditures under                
          section 174.  Additionally, because the activities of Utah I did             
          not constitute a trade or business, Utah I is not entitled to                
          deduct its losses in 1982 and 1983 as ordinary and necessary                 
          business expenses under section 162(a).  Respondent is sustained             
          on these issues.                                                             
               To reflect the foregoing,                                               

                                              Decision will be entered                
                                       for respondent.                                























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