Impact Research Corporation, Joan C. Benz, Tax Matters Person - Page 3




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          determined (1) a $241,700 adjustment3 resulting from the                    
          disallowance of a deduction for research or experimental                    
          expenditures under section 1744 and (2) an $80,000 adjustment               
          eliminating IRC’s reported short-term capital gain.  Petitioner             
          in docket No. 14872-98 does not dispute the $80,000 adjustment.             
          For RIC, respondent determined a $631,289 adjustment resulting              
          from the disallowance of a deduction for research or experimental           
          expenditures under section 174.5                                            


               3Under the heading of “Detail of Adjustments To Ordinary               
          Income”, the FSAA for IRC shows a $241,700 adjustment to research           
          and development expense.  Under the heading of “Other                       
          Adjustments”, the FSAA shows a $221,558 adjustment to research              
          and development expense and a $20,142 adjustment to qualified               
          investment expenses, paralleling the treatment on Schedule K,               
          Shareholders’ Share of Income, Credits, Deductions, etc., of                
          IRC’s 1984 S corporation tax return; the sum of these adjustments           
          is $241,700.  On brief, the parties treat this as one $241,700              
          adjustment.  For convenience, we follow the parties’ one-                   
          adjustment terminology.  This does not affect our substantive               
          analysis or our conclusions.                                                
               4Unless indicated otherwise, all section references are to             
          sections of the Internal Revenue Code of 1954 as in effect for              
          1984.                                                                       
               5Under the heading of “Detail of Adjustments To Ordinary               
          Income”, the FSAA for RIC shows a $631,289 adjustment to research           
          and development expense.  Under the heading of “Other                       
          Adjustments”, the FSAA shows a $594,192 adjustment to research              
          and development expense and a $37,097 adjustment to qualified               
          investment expenses, paralleling the treatment on Schedule K,               
          Shareholders’ Share of Income, Credits, Deductions, etc., of                
          RIC’s 1984 S corporation tax return; the sum of these adjustments           
          is $631,289.  However, on a “STATEMENT I” of RIC’s 1984 S                   
          corporation tax return, the deduction is broken down as follows:            
          (1) “research-development exp”--631,000, and (2) “other exp”--              
          289.  The parties do not appear to focus on the differences                 
          between these two breakdowns of the $631,289 total.  Because the            
                                                             (continued...)           





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