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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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