- 26 - 1964), affg. 41 T.C. 593 (1964); Tokarski v. Commissioner, 87 T.C. at 77; Williams v. Commissioner, supra. We find, therefore, that petitioners have failed to prove that the new solarium was constructed and used primarily for business reasons, and we sustain respondent’s determination disallowing the deduction.9 E. Miscellaneous Expenses Respondent disallowed miscellaneous deductions for expenses paid by Holland America attributable to the Dobbe residence. During FYE 1993, Holland America claimed a deduction for the entire amount of property tax, hazard insurance premiums, and the electricity bill associated with the property at 1066 South Pekin Road. After an examination, respondent determined the following amounts to be attributable to the Dobbe residence: Property tax ($2,054), hazard insurance premiums ($350), and electricity ($2,000).10 9Petitioners asserted, in the alternative, that the true purpose of the new solarium was to enable Holland America to conduct growing experiments; consequently, the expenditure qualified as a research and experimental expenditure under sec. 174(a). See sec. 263(a)(1)(B); sec. 1.174-2, Income Tax Regs. Except for a brief, one-sentence mention of sec. 174(a), however, Holland America has not presented any meaningful argument based on sec. 174(a), nor has it proved that it meets the requirements of sec. 174(a). 10Respondent’s witness, Susan Signor, a revenue agent, testified to the above amounts. At trial, petitioners’ attorney objected to the introduction of this evidence on the grounds of best evidence, competence, and relevance; however, petitioners did not dispute the accuracy of the amounts either at trial or on brief.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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