- 16 - reasonableness of the income projections, if any--other than Mr. Weiss' assurances to us that he thought that Oshtemo-Kalamazoo had a tremendous “upside” potential. In sum, petitioners' evidence falls far short of demonstrating that the Oshtemo- Kalamazoo program possessed the economic substance needed to support the tax deductions and credits at issue. We sustain respondent's determination as to this issue. Bases of Amortizable Assets The Internal Revenue Code permits taxpayers to claim deductions for amortization in specific situations, for example, the amortization of the cost of acquiring a lease under section 178. Section 1016 requires adjustments to basis with respect to amounts deducted as amortization expenses. Petitioners have provided no evidence with respect to the bases or costs of assets amortized by Oshtemo-Kalamazoo. We therefore have no cause to question respondent's disallowance of amortization deductions. Examination of Partnership Return On brief, petitioners attack respondent's disallowance by insisting that respondent disallowed the losses and credits claimed on their returns without initially making adjustments to the partnership Federal income tax returns. Even if true, petitioners' assertion does not avail them here. A trial before this Court is a proceeding de novo, and our determination as to petitioners' tax liability must be based on the merits of the case and not on any record developed at the administrative level. Greenberg's Express, Inc. v. Commissioner, 62 T.C. 324, 328Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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