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owned.
During the taxable years at issue, petitioner Tibor Guenther
Horwath (Mr. Horwath) occasionally provided consulting services
as a sole proprietorship known as “Tibor G. Horwath, Consulting”
(Tibor Horwath Consulting).
Claimed Depreciation Deductions
On June 24, 1992, TGC entered into contract DASG60-92-C-0069
(1992 contract) with the United States Army Strategic Defense
Command (SDC). During the course of the 1992 contract, SDC paid
TGC a total of $1,049,117.
The 1992 contract provided in pertinent part with respect to
the specific tasks to be completed pursuant to that contract:
The following specific tasks will be performed under
the proposed program:
Phase I:
(1) Design and construct an experimental
SSPG [small spinning projectile guid-
ance] seeker and associated laboratory
setup for open loop performance evalua-
tion of the concept against computer
generated and recorded, single and mul-
tiple target and background images.
(2) Evaluate the performance of the SSPG
seeker for various target and background
conditions, including the presence of
detector noise.
(3) Determine performance limits for the
SSPG seeker in terms of minimum detect-
able line of sight motion to the target,
and its ability to extract target fea-
ture information.
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