- 2 - business and is not entitled to a current deduction for his R&D expenses. Held, further, Ps did not adequately substantiate other deductions disallowed by R. Held, further, Ps are not liable for accuracy- related penalties associated with the deduction of R&D expenses. Ps are liable for accuracy-related penalties with respect to their failure to substantiate other disallowed deductions. Robert R. Rubin, for petitioners. Kathryn K. Vetter, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION RUWE, Judge: These cases were consolidated by motion of the parties for purposes of trial, briefing, and opinion. In docket No. 1821-00, respondent determined a deficiency in Federal income tax of $103,250 and a section 6662(a)1 accuracy-related penalty of $20,650 for the taxable year 1996 with respect to petitioner Computer Power Software Group, Inc. (CPSG, Inc.). In docket No. 555-00, respondent determined deficiencies in petitioners David M. and Teri L. Saykally’s2 income taxes, an addition to tax pursuant to section 6651(a)(1), and accuracy- 1All section references are to the Internal Revenue Code in effect for the taxable years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2Petitioners David M. and Teri L. Saykally filed joint Federal income tax returns for the taxable years at issue.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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