David D. Brayshaw and Nora D. Brayshaw - Page 14




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               Mr. Brayshaw did incur some expenses which we find to be               
          deductible.  In addition to the yacht’s normal berth, Mr.                   
          Brayshaw paid duplicative expenses in order to berth the yacht at           
          locations nearer to where he was required to take measurements.             
          We hold that petitioners are entitled to deduct under section               
          174(a) the following research and experimental expenses:                    
               Boat slip rental (check no. 1092)           $440                       
               Boat slip key (check no. 1065)                60                       
               Boat slip key (check no. 1096)                20                       
               Boat slip rental (check no. 3031)            340                       
               860                                                                    
               Finally, we come to miscellaneous items which petitioners              
          classified as being boat-related.  First, we hold that a $99.58             
          wristwatch purchased by Mr. Brayshaw is not a deductible expense:           
          We find that this was primarily a personal expense, despite the             
          watch’s occasional use in taking measurements of currents.  We              
          likewise hold that the “various boat supplies”, “boating                    
          literature”, and sealant for the boat are also personal expenses,           
          because there is little or no connection between the expenses and           
          Mr. Brayshaw’s research.  Furthermore, many of these expenses               
          could have been incurred in connection with petitioners’ sail               
          boat, rather than the yacht.                                                
               Computer-related expenses                                              
               Petitioners, both in their individual capacities and on                
          behalf of FDLS, purchased a variety of computer and computer-               
          related equipment during 1996, including a zip drive, a monitor,            
          a desktop computer, a facsimile machine, modems, and software.              





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