- 12 - Sec. 195(a). An exception to this general rule is made in the case of research and experimental expenses, which may be currently deductible under section 174(a) even before the advent of an active trade or business. Sec. 195(c); Snow v. Commissioner, 416 U.S. 500 (1974). We find that the majority of the expenses incurred in connection with the yacht are not deductible expenses, but rather are nondeductible personal expenses. See sec. 262(a). Mr. Brayshaw’s research essentially entailed using the boat to drift around the bay while taking measurements using global positioning equipment. It is doubtful that the use of a 34-foot yacht was necessary in making these measurements. More importantly, however, we do not accept petitioners’ assertion that they used the yacht exclusively for business purposes during the entire year, never deriving any personal use therefrom. In the absence of any contemporaneous substantiation of both the research and personal use of the boat, we hold that the interest paid in connection with the yacht (presumably for a purchase money loan), the cost of insuring the yacht, the cost of the yacht’s usual berth, and the costs of repairing and maintaining the yacht are not deductible. See sec. 274(d). Likewise, without addressing petitioners’ attempt to establish a basis in the yacht, petitioners are not entitled to depreciation deductions for the yacht. See id.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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