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Held, further: Ps are not entitled to claim a deduction
under sec. 162, I.R.C., with respect to the AdaCom program.
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 deficiencies of
$3,323, $3,556, and $3,126 in petitioners’ Federal income tax for
2000, 2001, and 2002, respectively.
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.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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