Robert J. and Sylvia Deward - Page 10




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          expenses related to researching a topic in order to write a book,           
          without more, are “start-up expenditures” within the meaning of             
          section 195.  Accordingly, we will sustain respondent’s                     
          determination to disallow the miscellaneous deductions of $15,892           
          on Mr. Deward’s Schedule C relating to amortization and the                 
          expenditures incurred for research for his book, including costs            
          for traveling to Europe.7  We will additionally sustain                     
          respondent’s adjustment of petitioners’ medical expense                     
          deductions and miscellaneous itemized deductions because of the             
          change in the determined amount of adjusted gross income.                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          













               7 Although we disallow the deductions in issue here, we note           
          that a taxpayer may elect to treat start-up expenditures as                 
          deferred expenses, deductible pro rata over a period of at least            
          60 months, beginning with the month in which the active trade or            
          business begins.  Sec. 195(b)(1).  We need not decide here                  
          whether Mr. Deward’s travel expenditures qualify for this                   
          treatment.                                                                  






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