Robert J. and Sylvia Deward - Page 4




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          journalist and writer for a major telecommunications company.4              
          He retired from that position in 1997.  Between 1997 and 2005,              
          Mr. Deward conducted research for a book that he plans to write             
          on World War I (WWI).  For 27 years, Mr. Deward has concentrated            
          on military tactics, model soldiers, and books relating to WWI.             
          He has also built up his own library on these subjects.  In 2001,           
          petitioners traveled to Europe for the purpose of conducting                
          research for the proposed WWI book.  At the time of respondent’s            
          examination of petitioners’ 2001 return in 2005, Mr. Deward had             
          not yet begun the actual writing of the book on WWI.  However, he           
          was still conducting research.                                              
               Petitioners timely filed their 2001 joint Federal income tax           
          return, including two Schedules C.  The first Schedule C relates            
          to Mr. Deward and lists his principal business as “Author”.  The            
          second Schedule C relates to petitioner Sylvia Deward and lists             
          her principal business as “Interior Design”.                                
               Respondent issued a timely notice of deficiency to                     
          petitioners for their 2001 tax year.  Respondent disallowed all             
          of the $15,892 of “other expenses” claimed on Mr. Deward’s                  
          Schedule C.  Those expenses consisted of $1,765 of amortization             
          and $14,127 for research and development.  The research and                 
          development deduction on Mr. Deward’s 2001 Schedule C consisted             


               4 The company has changed its name from Pacific Bell to                
          Pacific Telesis and is currently called SBC.                                






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