- 24 - uphold respondent’s determination disallowing the entire $34,246 deduction. D. Solarium (“Small Tools” Expense) Holland America spent $12,203 to construct a new solarium attached to the Dobbe residence and deducted the entire cost of the new solarium as a “small tools” expense. Petitioners argue that the new solarium was used solely for business purposes in the year the deduction was taken and that Holland America greatly benefited from the construction of the new solarium because the expense enabled it to experiment with and develop a new product, the medicinal herb Echinacea. Thus, petitioners contend, the expense properly was deductible under section 162(a) or, in the alternative, the new solarium was deductible as an experimental procedure under section 174(a). Respondent contends the new solarium benefited Mr. and Mrs. Dobbe personally and added value to their home; therefore, the new solarium was primarily aPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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