David M. and Teri L. Saykally - Page 2

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               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.                  




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