G.B. Data Systems, Inc. - Page 10




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          Respondent also determined that petitioner was liable for that                
          taxable year for the accuracy-related penalty under section                   
          6662(a).                                                                      
                                        OPINION                                         
               Petitioner bears the burden of proving that the determina-               
          tions in the notice are erroneous.  See Rule 142(a); Welch v.                 
          Helvering, 290 U.S. 111, 115 (1933).                                          
          Claimed Royalty Expense Deduction                                             
               Petitioner contends that it is entitled under section 162(a)             
          to deduct for the year at issue the royalty expense claimed in                
          the Form 1120 that it filed for that year.  Respondent counters               
          that petitioner has failed to establish that it satisfies the                 
          requirements of section 162(a).  Respondent also contends that                
          petitioner has failed to prove that it satisfies the all events               
          test with respect to the claimed royalty expense.  See sec.                   
          461(a) and (h).  On the record before us, we agree with respon-               
          dent.                                                                         
               Section 162(a) allows a taxpayer to deduct all the ordinary              
          and necessary expenses that such taxpayer paid or incurred during             
          the taxable year in carrying on such taxpayer’s trade or busi-                
          ness.  Deductions are strictly a matter of legislative grace, and             
          a taxpayer must meet the specific statutory requirements for any              
          deduction claimed.  See INDOPCO, Inc. v. Commissioner, 503 U.S.               
          79, 84 (1992).  The determination of whether an expenditure                   






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