Michael H. Visin and Natalie Marselly - Page 13

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          will be that much less restrictive.                                         
               In view of the foregoing, we hold that petitioners are not             
          entitled to expense the cost of the computer equipment and                  
          software.  Respondent’s determination capitalizing the cost of              
          such property and allowing depreciation thereon is sustained.               
               C.  Conclusion                                                         
               To reflect the foregoing,                                              


                                             Decision will be entered                 
                                        under Rule 155.                               





























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