- 48 - 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.Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48
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