- 3 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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