- 13 - $56,250. On its Federal income tax return for 1983, Research II claimed a $231,432.45 loss consisting of $1,628.83 of dividend income and miscellaneous expenses of $233,061.28. On its Federal income tax return for 1984, Research II claimed a $174,571.15 loss consisting of $257.18 of dividend income and miscellaneous expenses of $174,828.33. By notice of final partnership administrative adjustment dated July 8, 1988, respondent denied Research II's deductions for the years in issue but allowed Research II a deduction of $25,931 for amortization of patents in 1984. Respondent has stipulated that Research II was entitled pursuant to section 709(b) to deduct amortization of organizational fees of $1,250 for 1982. OPINION The issue we must decide is whether Research II is entitled to a deduction, pursuant to section 174(a)(1), for the $2,750,000 debt it incurred to CemCom during 1982. Section 174(a)(1) provides: SEC. 174(a). Treatment as Expenses.–- (1) In general.--A taxpayer may treat research or experimental expenditures which are paid or incurred by him during the taxable year in connection with his trade or business as expenses which are not chargeable to capital account. The expenditures so treated shall be allowed as a deduction. The parties agree that the $2,750,000 debt related to research or experimentation falls within the scope of section 174. Respondent contends, however, that the debt was notPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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