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Scott M. Estill and Stephanie F. Long, for petitioners.
Richard D. D’Estrada, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$1,935 in petitioners’ Federal income tax for 2000.
The issues for decision are:
(1) Whether petitioners are entitled to claim a tax credit
pursuant to sections 381 and 44 for their subscription to the
AdaCom program (program);
(2) whether petitioners are entitled to claim a trade or
business expense deduction under section 162 with respect to the
program; and
(3) if petitioners are entitled to a credit and/or deduction
for their investment in the program, the proper valuation of the
program.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
the petition, petitioners resided in Denver, Colorado.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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