David M. and Teri L. Saykally - Page 13

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               During 1995 and 1996, CPSG, Inc., by and through its wholly            
          owned subsidiaries, paid $67,543 and $1,361,006 of research and             
          development costs on behalf of petitioner.  These costs included:           
               Description           1995            1996                             
               Salaries1           $28,584        $1,076,850                          
               Contract labor      20,947         46,451                              
               Building rent       5,644          54,293                              
               Commissions         4,250          3,306                               
               Telephone           428            33,001                              
               Entertainment       106                 659                            
               Equipment rental    6,052          68,379                              
               Repairs/maintenance 1,036          26,086                              
               Freight             497                 265                            
               Janitorial          -0-                 426                            
               Recruiting fees     -0-            4,187                               
               Travel              -0-            3,016                               
               Services            -0-            13,495                              
               Dues & subscriptions-0-            1,500                               
               Electricity         -0-            14,218                              
               License fees        -0-            12,050                              
               Small equipment     -0-                 573                            
               Office supplies     -0-            1,761                               
               Postage/misc.       -0-                 491                            
               1The category “Salaries” represents the cumulative amount paid to      
          individuals living in Australia.                                            
          CPSG, Inc. used its accounting system to track these costs.                 
          CPSG, Inc. initially deducted these research and development                
          costs on its Federal income tax return for the year ended                   
          September 30, 1996.  CPSG, Inc. subsequently amended its 1996               
          return eliminating the deduction.                                           
               Petitioners attached Schedules C for a computer software               
          development business named “DMS Development Co.” to their 1995              
          and 1996 returns.  For the years at issue, petitioners reported             










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