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the meaning of section 44(c), and, consequently, they do not
qualify for the disabled access credit. Respondent’s
determination is sustained.
Because we conclude that petitioners’ subscription to the
program does not constitute an eligible access expenditure, it is
unnecessary for us to decide whether petitioners’ activities
constituted an eligible small business or the proper valuation of
the program.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011