- 11 - 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;Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011