Ronna Joan Robertson - Page 11




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          Accordingly, petitioner is entitled to deduct the mortgage                  
          interest paid in 1993 and 1994.                                             
               F. Delaware Corporation Startup Expenses                               
               Petitioner contends that she is allowed to deduct Delaware             
          corporation startup expenses and submitted documentation                    
          concerning a corporation known as Worldly Connections, Inc.  The            
          documentation submitted indicates that in January 1994 petitioner           
          paid $248.95 for Delaware State filing fees, registered agent               
          fees, a corporate kit, and basic mail forwarding service.                   
          Petitioner also remitted an additional $155 in November 1994 for            
          advanced payment of agent fees and renewal filing fees.                     
               Section 248 permits a corporation to elect to amortize on              
          its corporation income tax return its organizational expenditures           
          over a period of 60 months or more from the month in which the              
          corporation began business.  The term “organizational                       
          expenditures” is defined to mean any expenditure that is (1)                
          incident to the creation of the corporation; (2) chargeable to a            
          capital account; and (3) of a character that, if expended                   
          incident to the creation of a corporation having a limited life,            
          would be amortizable over such life.  Sec. 248(b).                          
               Organizational costs that are paid by the shareholder of a             
          corporation do not normally qualify for amortization under                  
          section 248 but, instead, must be capitalized as part of the                
          shareholder’s stock basis.  Cf., e.g., Deputy v. du Pont, supra;            






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